QA Investigation Results

Pennsylvania Department of Health
ALWAYS A STEP BEYOND
Health Inspection Results
ALWAYS A STEP BEYOND
Health Inspection Results For:


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Initial Comments:
Name - Component - -- Based on the findings of an unannounced onsite Medicare recertification survey conducted on February 9, 2026, February 10, 2026, and conducted off-site February 11, 2026, February 13, 2026 and February 27, 2026, Always A Step Beyond, was found to not be in compliance with the requirements of 42 CFR, Part 484.22, Subpart B, Conditions of Participation: Home Health Agencies - Emergency Preparedness.As a result of the survey, one (1) condition level citation was issued at 484.102 Establishment of the Emergency Program but did not result in the identification of an immediate jeopardy. 
Plan of Correction:




484.102 CONDITION
Establishment of the Emergency Program (EP)

Name - Component - --
§403.748, §416.54, §418.113, §441.184, §460.84, §482.15, §483.73, §483.475, §484.102, §485.68, §485.542, §485.625, §485.727, §485.920, §486.360, §491.12

The [facility, except for Transplant Programs] must comply with all applicable Federal, State and local emergency preparedness requirements. The [facility, except for Transplant Programs] must establish and maintain a [comprehensive] emergency preparedness program that meets the requirements of this section.* The emergency preparedness program must include, but not be limited to, the following elements:

* (Unless otherwise indicated, the general use of the terms "facility" or "facilities" in this Appendix refers to all provider and suppliers addressed in this appendix. This is a generic moniker used in lieu of the specific provider or supplier noted in the regulations. For varying requirements, the specific regulation for that provider/supplier will be noted as well.)

*[For hospitals at §482.15:] The hospital must comply with all applicable Federal, State, and local emergency preparedness requirements. The hospital must develop and maintain a comprehensive emergency preparedness program that meets the requirements of this section, utilizing an all-hazards approach. The emergency preparedness program must include, but not be limited to, the following elements:

*[For CAHs at §485.625:] The CAH must comply with all applicable Federal, State, and local emergency preparedness requirements. The CAH must develop and maintain a comprehensive emergency preparedness program, utilizing an all-hazards approach. The emergency preparedness program must include, but not be limited to, the following elements:

Observations: Based on review of agency policies/procedures, emergency preparedness program manual (EP) and an interview with the Administrator/Director of Nursing (PF#1), the agency failed to establish and maintain a comprehensive emergency preparedness program (Tag 004); failed to ensure the completion of an all-hazards risk assessment every two (2) years (Tag 006); failed to specify the population served (Tag 009); failed to maintain documentation of initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers at least every two (2) years (Tag 0036): failed to ensure documentation to test the emergency plan annually (Tag 0037); failed to to test the emergency plan annually, which includes a full-scale exercise that is community-based every 2 years and an additional exercise at least every 2 years, opposite the year of the full-scale exercise for one (1) of one (1) EP reviewed EP #1. Findings include: Cross references: 484.102 (a) E-0004 Development of Emergency Preparedness Plan Review and Update Annually, the agency failed to review and update the emergency preparedness plan at least every two (2) years. 484.102(a)(1-2) E-0006 Program based on All Hazards Risk Assessment- the agency failed to complete an all-hazards risk assessment at least every two (2) years. 484.102(a)(3) E-0007 EP Program Patient Population- the agency failed to specify the population served by the agency one (1) of one (1) plan reviewed EP #1 484.102 (d) E-0036 EP Training and Testing-the agency failed to maintain documentation of initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, and no documentation of emergency preparedness training conducted at least every two (2) years. 484.102(d)(1)E-0037 EP Training Program-the agency failed to document exercises to test the emergency plan annually, which includes a full-scale exercise that is community-based every 2 years and an additional exercise at least every 2 years, opposite the year of the full-scale exercise. 484.102(d)(2) E-0039 EP Testing Requirements the agency failed to document exercises to test the emergency plan annually, which includes a full-scale exercise that is community-based every 2 years and an additional exercise at least every 2 years, opposite the year of the full-scale exercise. The agency's failure to develop, review and maintain a comprehensive emergency preparedness program led to it's inability to provide effective and safe patient care.

Plan of Correction:

The agency failed to establish and maintain a comprehensive emergency preparedness program, including failure to conduct an all-hazards risk assessment, define the patient population served, maintain staff training documentation, and conduct and document required emergency preparedness exercises.
All active patients were reviewed to identify those at higher risk during emergencies. An emergency contact verification was completed for all active patients. Patients and/or caregivers were provided education on emergency preparedness. Updated emergency contact sheets and individualized emergency plans were placed in each patient's clinical record.
To identify additional patients who may have been affected by the deficient practice, the agency conducted a review of all active patient records. Any missing or incomplete information was corrected, and patients were contacted to update emergency planning documentation.
To prevent recurrence the agency completed a full revision of its Emergency Preparedness Program to ensure compliance with the regulations. All new employees receive emergency preparedness training at orientation. All staff, contractors, and volunteers receive refresher training at least every two (2) years. The agency has implemented a testing schedule that includes per regulations.
To ensure sustained compliance and prevent recurrence, the agency has incorporated emergency preparedness oversight into its Quality Assurance and Performance Improvement (QAPI) program. The Administrator will conduct semi-annual reviews of the emergency preparedness plan, verify completion of required training and exercises and review patient emergency preparedness documentation during quarterly clinical record audits. Emergency preparedness compliance will be reviewed during quarterly QAPI meetings any identified deficiencies will result in immediate corrective action and staff retraining.
To identify additional patients who may have been affected by the deficient practice, the agency conducted a review of all active patient records. Any missing or incomplete information was corrected, and patients were contacted to update emergency planning documentation.
To prevent recurrence the agency completed a full revision of its Emergency Preparedness Program to ensure compliance with the regulations. All new employees receive emergency preparedness training at orientation. All staff, contractors, and volunteers receive refresher training at least every two (2) years. The agency has implemented a testing schedule that includes per regulations.




484.102(a) STANDARD
Develop EP Plan, Review and Update Annually

Name - Component - --
§403.748(a), §416.54(a), §418.113(a), §441.184(a), §460.84(a), §482.15(a), §483.73(a), §483.475(a), §484.102(a), §485.68(a), §485.542(a), §485.625(a), §485.727(a), §485.920(a), §486.360(a), §491.12(a), §494.62(a).

The [facility] must comply with all applicable Federal, State and local emergency preparedness requirements. The [facility] must develop establish and maintain a comprehensive emergency preparedness program that meets the requirements of this section. The emergency preparedness program must include, but not be limited to, the following elements:

(a) Emergency Plan. The [facility] must develop and maintain an emergency preparedness plan that must be [reviewed], and updated at least every 2 years. The plan must do all of the following:

* [For hospitals at §482.15 and CAHs at §485.625(a):] Emergency Plan. The [hospital or CAH] must comply with all applicable Federal, State, and local emergency preparedness requirements. The [hospital or CAH] must develop and maintain a comprehensive emergency preparedness program that meets the requirements of this section, utilizing an all-hazards approach.

* [For LTC Facilities at §483.73(a):] Emergency Plan. The LTC facility must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually.

* [For ESRD Facilities at §494.62(a):] Emergency Plan. The ESRD facility must develop and maintain an emergency preparedness plan that must be [evaluated], and updated at least every 2 years.

.

Observations: Based on review of policies/procedures, agency emergency preparedness documentation and interview with agency staff, the agency failed to review and update the emergency preparedness plan at least every two (2) years. Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed a policy titled "Emergency Preparedness Plan Orientation/In-Service Training" dated 7/2017. There was no documentation that the plan was reviewed and/or updated every two (2) years. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency conducted an immediate review and complete revision of the Emergency Preparedness Plan to ensure current practices, contact information, and procedures were accurate and reflective of present operations. The updated plan now reflects current patient care services, geographic service area, communication methods, and coordination with local emergency management agencies.
All active patients were provided updated emergency preparedness education and emergency contact information to ensure they are aware of current agency emergency procedures. Because the emergency preparedness plan applies to all patients served by the agency, the agency conducted a review of all active patient records to ensure compliance with the regulations. Any missing or outdated information was corrected and documented in the patient's clinical record. To prevent recurrence the Emergency Preparedness Plan will be reviewed and updated in accordance with the regulations.
The agency has implemented a compliance tracking log to maintain compliance with the requirements. This log is maintained by the Administrator and reviewed during quarterly management meetings.
The agency has incorporated emergency preparedness plan review into its Quality Assurance and Performance Improvement (QAPI) program. The Administrator will review the emergency preparedness plan annually to ensure ongoing relevance
The status of the emergency preparedness plan review will be reported during quarterly QAPI meetings to ensure compliance with the requirements. Any missed deadlines or deficiencies will result in immediate corrective action and administrative review.



484.102(a)(1)-(2) STANDARD
Plan Based on All Hazards Risk Assessment

Name - Component - --
§403.748(a)(1)-(2), §416.54(a)(1)-(2), §418.113(a)(1)-(2), §441.184(a)(1)-(2), §460.84(a)(1)-(2), §482.15(a)(1)-(2), §483.73(a)(1)-(2), §483.475(a)(1)-(2), §484.102(a)(1)-(2), §485.68(a)(1)-(2), §485.542(a)(1)-(2), §485.625(a)(1)-(2), §485.727(a)(1)-(2), §485.920(a)(1)-(2), §486.360(a)(1)-(2), §491.12(a)(1)-(2), §494.62(a)(1)-(2)

[(a) Emergency Plan. The [facility] must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:]

(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.*

(2) Include strategies for addressing emergency events identified by the risk assessment.

* [For Hospices at §418.113(a):] Emergency Plan. The Hospice must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:
(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach.
(2) Include strategies for addressing emergency events identified by the risk assessment, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice's ability to provide care.

*[For LTC facilities at §483.73(a):] Emergency Plan. The LTC facility must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must do the following:
(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing residents.
(2) Include strategies for addressing emergency events identified by the risk assessment.

*[For ICF/IIDs at §483.475(a):] Emergency Plan. The ICF/IID must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:

(1) Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach, including missing clients.
(2) Include strategies for addressing emergency events identified by the risk assessment.

Observations: Based on review of policies/procedures, agency emergency preparedness documentation and interview with agency staff, the agency failed to complete an all-hazards risk assessment at least every two (2) years. Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed a "Hazard Risk Analysis" form for 2017. There was no documentation that an all-hazards risk assessment was completed every two (2) years. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has implemented corrective actions to ensure that its emergency preparedness plan is based on a documented facility-based and community-based all-hazards risk assessment, completed and updated at least every two (2) years in accordance with 42 CFR §484.102(a)(1)–(2). Systems have been implemented to ensure ongoing compliance and prevent recurrence. The agency conducted a comprehensive facility-based and community-based all-hazards risk assessment to identify threats that could affect operations and patient safety, based on the findings of the risk assessment, emergency response strategies were updated to address identified hazards. High-risk patients, including those dependent on electricity or requiring frequent skilled visits, were identified and flagged in their clinical records for priority response during emergencies.

The agency conducted a review of all active patient records to ensure compliance with the requirements, any missing information was obtained and documented.
To ensure compliance with the requirement the agency implemented a hazards risk assessment tool to identify hazards with specific response strategies.
The Administrator and or the Director of Nursing will be responsibility for completion of the risk assessment and review to ensure clinical risks are fully addressed.
The agency has incorporated risk assessment review into its ongoing Quality Assurance and Performance Improvement (QAPI) program. The Administrator will review the status of the all-hazards risk assessment annually and ensure a full assessment is completed no later than two years from the most recent assessment date. The risk assessment and any resulting changes to the emergency preparedness plan will be reviewed during quarterly QAPI meetings to ensure compliance with the requirements.
Any missed deadlines will be addressed through corrective action and administrative review.



484.102(a)(3) STANDARD
EP Program Patient Population

Name - Component - --
§403.748(a)(3), §416.54(a)(3), §418.113(a)(3), §441.184(a)(3), §460.84(a)(3), §482.15(a)(3), §483.73(a)(3), §483.475(a)(3), §484.102(a)(3), §485.68(a)(3), §485.542(a)(3), §485.625(a)(3), §485.727(a)(3), §485.920(a)(3), §491.12(a)(3), §494.62(a)(3).

[(a) Emergency Plan. The [facility] must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least every 2 years. The plan must do the following:]

(3) Address [patient/client] population, including, but not limited to, persons at-risk; the type of services the [facility] has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.**

*[For LTC facilities at §483.73(a):] Emergency Plan. The LTC facility must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually. The plan must do all of the following:
(3) Address resident population, including, but not limited to, persons at-risk; the type of services the LTC facility has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.

*NOTE: ["Persons at risk" does not apply to: ASC, hospice, PACE, HHA, CORF, CMCH, RHC/FQHC, or ESRD facilities.]

Observations: Based on review of agency emergency preparedness documentation and interview with agency staff, the agency failed to specify the population served by the agency one (1) of one (1) plan reviewed EP #1 Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed no documentation of a plan that is specific to the population served by the agency. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has revised its Emergency Preparedness Plan to ensure that it clearly defines the patient population served, the services that can be provided during emergencies, and continuity of operations. Systems have been implemented to ensure that the plan remains current and is reviewed and updated in accordance with the requirements.
The agency revised its Emergency Preparedness Plan to include a detailed description of the patient population served. Each active patient's clinical record was reviewed to ensure that individualized emergency planning information was present and current. Patients and caregivers were re-educated on agency emergency procedures and how services would be modified or continued during an emergency.

The agency conducted a review of all active patient clinical records. Any missing or outdated information was corrected and documented in the clinical record.

To prevent recurrence patients population profile will be reviewed during each biennial emergency preparedness plan review.

To ensure ongoing compliance, the agency has incorporated emergency preparedness patient population review into its Quality Assurance and Performance Improvement (QAPI) program.

The Administrator and Director of Nursing will review patient population characteristics during quarterly clinical record audits and verify that emergency preparedness documentation remains aligned with the current patient census and service types. During quarterly QAPI meetings the emergency preparedness plan will be reviewed to confirm that it accurately reflects current patient needs, any identified changes in patient acuity, service types, or geographic coverage will trigger plan updates.




484.102(d) STANDARD
EP Training and Testing

Name - Component - --
§403.748(d), §416.54(d), §418.113(d), §441.184(d), §460.84(d), §482.15(d), §483.73(d), §483.475(d), §484.102(d), §485.68(d), §485.542(d), §485.625(d), §485.727(d), §485.920(d), §486.360(d), §491.12(d), §494.62(d).

*[For RNCHIs at §403.748, ASCs at §416.54, Hospice at §418.113, PRTFs at §441.184, PACE at §460.84, Hospitals at §482.15, HHAs at §484.102, CORFs at §485.68, REHs at §485.542, CAHs at §486.625, "Organizations" under 485.727, CMHCs at §485.920, OPOs at §486.360, and RHC/FHQs at §491.12:] (d) Training and testing. The [facility] must develop and maintain an emergency preparedness training and testing program that is based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, policies and procedures at paragraph (b) of this section, and the communication plan at paragraph (c) of this section. The training and testing program must be reviewed and updated at least every 2 years.

*[For LTC facilities at §483.73(d):] (d) Training and testing. The LTC facility must develop and maintain an emergency preparedness training and testing program that is based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, policies and procedures at paragraph (b) of this section, and the communication plan at paragraph (c) of this section. The training and testing program must be reviewed and updated at least annually.

*[For ICF/IIDs at §483.475(d):] Training and testing. The ICF/IID must develop and maintain an emergency preparedness training and testing program that is based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, policies and procedures at paragraph (b) of this section, and the communication plan at paragraph (c) of this section. The training and testing program must be reviewed and updated at least every 2 years. The ICF/IID must meet the requirements for evacuation drills and training at §483.470(i).

*[For ESRD Facilities at §494.62(d):] Training, testing, and orientation. The dialysis facility must develop and maintain an emergency preparedness training, testing and patient orientation program that is based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, policies and procedures at paragraph (b) of this section, and the communication plan at paragraph (c) of this section. The training, testing and orientation program must be evaluated and updated at every 2 years.

Observations: Based on review of agency emergency preparedness documentation and interview with agency staff, the agency failed to develop and maintain an emergency preparedness training and testing program that is based on the emergency preparedness plan, the risk assessment, policies and procedures, and the communication plan, which must be reviewed and updated at least every two (2) years. Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed an "Emergency Preparedness In-Service Quiz". There was no documentation that the training and testing program was reviewed and updated at least every two (2) years. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has implemented a comprehensive emergency preparedness training and testing program that is based on the emergency preparedness plan, all-hazards risk assessment, policies and procedures, and communication plan. Systems have been established to ensure the program is reviewed and updated at least every two (2) years in compliance with the regulations and that staff remain prepared to respond effectively during emergencies.

All active patients were reviewed to ensure emergency contact information, individualized emergency plans, and priority status were current. Staff were immediately re-educated on emergency procedures, including patient communication, evacuation considerations, and continuity of care during emergencies. Updated emergency preparedness information was communicated to patients and caregivers to ensure they understood how services would be provided or modified during an emergency.

The agency conducted a review of all active patient clinical records. Any missing documentation was corrected and entered into the clinical record.

To prevent recurrence the agency developed and implemented a comprehensive Emergency Preparedness Training and Testing Program aligned with the emergency preparedness plan, all-hazards risk assessment, policies and procedures, and communication plan.

The agency incorporated emergency preparedness training oversight into its Quality Assurance and Performance Improvement (QAPI) program to ensure the deficiency does not recur.

The Administrator will review training records quarterly to ensure all staff remain compliant with required training intervals. Verify that new hires receive emergency preparedness training during orientation. Quarterly QAPI meetings will be performed for compliance with the regulations.



484.102(d)(1) STANDARD
EP Training Program

Name - Component - --
§403.748(d)(1), §416.54(d)(1), §418.113(d)(1), §441.184(d)(1), §460.84(d)(1), §482.15(d)(1), §483.73(d)(1), §483.475(d)(1), §484.102(d)(1), §485.68(d)(1), §485.542(d)(1), §485.625(d)(1), §485.727(d)(1), §485.920(d)(1), §486.360(d)(1), §491.12(d)(1).

*[For RNCHIs at §403.748, ASCs at §416.54, Hospitals at §482.15, ICF/IIDs at §483.475, HHAs at §484.102, REHs at §485.542, "Organizations" under §485.727, OPOs at §486.360, RHC/FQHCs at §491.12:]
(1) Training program. The [facility] must do all of the following:
(i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.
(ii) Provide emergency preparedness training at least every 2 years.
(iii) Maintain documentation of all emergency preparedness training.
(iv) Demonstrate staff knowledge of emergency procedures.
(v) If the emergency preparedness policies and procedures are significantly updated, the [facility] must conduct training on the updated policies and procedures.

*[For Hospices at §418.113(d):] (1) Training. The hospice must do all of the following:
(i) Initial training in emergency preparedness policies and procedures to all new and existing hospice employees, and individuals providing services under arrangement, consistent with their expected roles.
(ii) Demonstrate staff knowledge of emergency procedures.
(iii) Provide emergency preparedness training at least every 2 years.
(iv) Periodically review and rehearse its emergency preparedness plan with hospice employees (including nonemployee staff), with special emphasis placed on carrying out the procedures necessary to protect patients and others.
(v) Maintain documentation of all emergency preparedness training.
(vi) If the emergency preparedness policies and procedures are significantly updated, the hospice must conduct training on the updated policies and
procedures.

*[For PRTFs at §441.184(d):] (1) Training program. The PRTF must do all of the following:
(i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.
(ii) After initial training, provide emergency preparedness training every 2 years.
(iii) Demonstrate staff knowledge of emergency procedures.
(iv) Maintain documentation of all emergency preparedness training.
(v) If the emergency preparedness policies and procedures are significantly updated, the PRTF must conduct training on the updated policies and procedures.

*[For PACE at §460.84(d):] (1) The PACE organization must do all of the following:
(i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing on-site services under arrangement, contractors, participants, and volunteers, consistent with their expected roles.
(ii) Provide emergency preparedness training at least every 2 years.
(iii) Demonstrate staff knowledge of emergency procedures, including informing participants of what to do, where to go, and whom to contact in case of an emergency.
(iv) Maintain documentation of all training.
(v) If the emergency preparedness policies and procedures are significantly updated, the PACE must conduct training on the updated policies and procedures.

*[For LTC Facilities at §483.73(d):] (1) Training Program. The LTC facility must do all of the following:
(i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected role.
(ii) Provide emergency preparedness training at least annually.
(iii) Maintain documentation of all emergency preparedness training.
(iv) Demonstrate staff knowledge of emergency procedures.

*[For CORFs at §485.68(d):](1) Training. The CORF must do all of the following:
(i) Provide initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.
(ii) Provide emergency preparedness training at least every 2 years.
(iii) Maintain documentation of the training.
(iv) Demonstrate staff knowledge of emergency procedures. All new personnel must be oriented and assigned specific responsibilities regarding the CORF's emergency plan within 2 weeks of their first workday. The training program must include instruction in the location and use of alarm systems and signals and firefighting equipment.
(v) If the emergency preparedness policies and procedures are significantly updated, the CORF must conduct training on the updated policies and procedures.

*[For CAHs at §485.625(d):] (1) Training program. The CAH must do all of the following:
(i) Initial training in emergency preparedness policies and procedures, including prompt reporting and extinguishing of fires, protection, and where necessary, evacuation of patients, personnel, and guests, fire prevention, and cooperation with firefighting and disaster authorities, to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.
(ii) Provide emergency preparedness training at least every 2 years.
(iii) Maintain documentation of the training.
(iv) Demonstrate staff knowledge of emergency procedures.
(v) If the emergency preparedness policies and procedures are significantly updated, the CAH must conduct training on the updated policies and procedures.

*[For CMHCs at §485.920(d):] (1) Training. The CMHC must provide initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles, and maintain documentation of the training. The CMHC must demonstrate staff knowledge of emergency procedures. Thereafter, the CMHC must provide emergency preparedness training at least every 2 years.

Observations: Based on review of agency emergency preparedness documentation and interview with agency staff, the agency failed to maintain documentation of initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, and no documentation of emergency preparedness training conducted at least every two (2) years. Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed no documentation of initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers. There was no documentation that emergency preparedness training was conducted at least every two (2) years. The agency did not maintain documentation of all emergency preparedness training and demonstration of staff knowledge of emergency procedures. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has implemented a comprehensive emergency preparedness training program in compliance with the regulations. Systems are in place to ensure initial training, biennial refresher training, competency demonstration, and documentation are maintained. Monitoring through QAPI ensures sustainability and prevents recurrence.

All active staff, contractors, and volunteers were provided comprehensive emergency preparedness training consistent with their roles. All active patients' records were reviewed to ensure emergency contact information and individual care plans were current. Any gaps were corrected and documented. All patients and caregivers were informed of emergency procedures and what to expect in case of an emergency to ensure continuity of care.

The agency conducted a full review of all active patients to ensure emergency preparedness plans were current. For any patient whose record lacked updated emergency preparedness documentation, entries were corrected, and staff were instructed to maintain ongoing updates for future changes.

To prevent future deficiencies, the agency has implemented training to all new hires, contractors, and volunteers during orientation on emergency preparedness policies, procedures, and staff roles. All staff will receive emergency preparedness training per agency policy.

The agency has established ongoing monitoring through its QAPI program. The Administrator will review training logs quarterly to ensure all staff are current. A report summarizing training compliance and any corrective actions will be reviewed in QAPI meetings.




484.102(d)(2) STANDARD
EP Testing Requirements

Name - Component - --
§416.54(d)(2), §418.113(d)(2), §441.184(d)(2), §460.84(d)(2), §482.15(d)(2), §483.73(d)(2), §483.475(d)(2), §484.102(d)(2), §485.68(d)(2), §485.542(d)(2), §485.625(d)(2), §485.727(d)(2), §485.920(d)(2), §491.12(d)(2), §494.62(d)(2).

*[For ASCs at §416.54, CORFs at §485.68, REHs at §485.542, OPO, "Organizations" under §485.727, CMHCs at §485.920, RHCs/FQHCs at §491.12, and ESRD Facilities at §494.62]:

(2) Testing. The [facility] must conduct exercises to test the emergency plan annually. The [facility] must do all of the following:

(i) Participate in a full-scale exercise that is community-based every 2 years; or
(A) When a community-based exercise is not accessible, conduct a facility-based functional exercise every 2 years; or
(B) If the [facility] experiences an actual natural or man-made emergency that requires activation of the emergency plan, the [facility] is exempt from engaging in its next required community-based or individual, facility-based functional exercise following the onset of the actual event.
(ii) Conduct an additional exercise at least every 2 years, opposite the year the full-scale or functional exercise under paragraph (d)(2)(i) of this section is conducted, that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or individual, facility-based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the [facility's] response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the [facility's] emergency plan, as needed.

*[For Hospices at 418.113(d):]
(2) Testing for hospices that provide care in the patient's home. The hospice must conduct exercises to test the emergency plan at least annually. The hospice must do the following:
(i) Participate in a full-scale exercise that is community based every 2 years; or
(A) When a community based exercise is not accessible, conduct an individual facility based functional exercise every 2 years; or
(B) If the hospice experiences a natural or man-made emergency that requires activation of the emergency plan, the hospital is exempt from engaging in its next required full scale community-based exercise or individual facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an additional exercise every 2 years, opposite the year the full-scale or functional exercise under paragraph (d)(2)(i) of this section is conducted, that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or a facility based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.

(3) Testing for hospices that provide inpatient care directly. The hospice must conduct exercises to test the emergency plan twice per year. The hospice must do the following:
(i) Participate in an annual full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual facility-based functional exercise; or
(B) If the hospice experiences a natural or man-made emergency that requires activation of the emergency plan, the hospice is exempt from engaging in its next required full-scale community based or facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an additional annual exercise that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or a facility based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop led by a facilitator that includes a group discussion using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the hospice's response to and maintain documentation of all drills, tabletop exercises, and emergency events and revise the hospice's emergency plan, as needed.


*[For PRFTs at §441.184(d), Hospitals at §482.15(d), CAHs at §485.625(d):]
(2) Testing. The [PRTF, Hospital, CAH] must conduct exercises to test the emergency plan twice per year. The [PRTF, Hospital, CAH] must do the following:
(i) Participate in an annual full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual, facility-based functional exercise; or
(B) If the [PRTF, Hospital, CAH] experiences an actual natural or man-made emergency that requires activation of the emergency plan, the [facility] is exempt from engaging in its next required full-scale community based or individual, facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an [additional] annual exercise or and that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or individual, a facility-based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the [facility's] response to and maintain documentation of all drills, tabletop exercises, and emergency events and revise the [facility's] emergency plan, as needed.

*[For PACE at §460.84(d):]
(2) Testing. The PACE organization must conduct exercises to test the emergency plan at least annually. The PACE organization must do the following:
(i) Participate in an annual full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual, facility-based functional exercise; or
(B) If the PACE experiences an actual natural or man-made emergency that requires activation of the emergency plan, the PACE is exempt from engaging in its next required full-scale community based or individual, facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an additional exercise every 2 years opposite the year the full-scale or functional exercise under paragraph (d)(2)(i) of this section is conducted that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or individual, a facility based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the PACE's response to and maintain documentation of all drills, tabletop exercises, and emergency events and revise the PACE's emergency plan, as needed.

*[For LTC Facilities at §483.73(d):]
(2) The [LTC facility] must conduct exercises to test the emergency plan at least twice per year, including unannounced staff drills using the emergency procedures. The [LTC facility, ICF/IID] must do the following:
(i) Participate in an annual full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual, facility-based functional exercise.
(B) If the [LTC facility] facility experiences an actual natural or man-made emergency that requires activation of the emergency plan, the LTC facility is exempt from engaging its next required a full-scale community-based or individual, facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an additional annual exercise that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or an individual, facility based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator includes a group discussion, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the [LTC facility] facility's response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the [LTC facility] facility's emergency plan, as needed.

*[For ICF/IIDs at §483.475(d)]:
(2) Testing. The ICF/IID must conduct exercises to test the emergency plan at least twice per year. The ICF/IID must do the following:
(i) Participate in an annual full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual, facility-based functional exercise; or.
(B) If the ICF/IID experiences an actual natural or man-made emergency that requires activation of the emergency plan, the ICF/IID is exempt from engaging in its next required full-scale community-based or individual, facility-based functional exercise following the onset of the emergency event.
(ii) Conduct an additional annual exercise that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or an individual, facility-based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the ICF/IID's response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the ICF/IID's emergency plan, as needed.

*[For HHAs at §484.102]
(d)(2) Testing. The HHA must conduct exercises to test the emergency plan at
least annually. The HHA must do the following:
(i) Participate in a full-scale exercise that is community-based; or
(A) When a community-based exercise is not accessible, conduct an annual individual, facility-based functional exercise every 2 years; or.
(B) If the HHA experiences an actual natural or man-made emergency that requires activation of the emergency plan, the HHA is exempt from engaging in its next required full-scale community-based or individual, facility based functional exercise following the onset of the emergency event.
(ii) Conduct an additional exercise every 2 years, opposite the year the full-scale or functional exercise under paragraph (d)(2)(i) of this section is conducted, that may include, but is not limited to the following:
(A) A second full-scale exercise that is community-based or an individual, facility-based functional exercise; or
(B) A mock disaster drill; or
(C) A tabletop exercise or workshop that is led by a facilitator and includes a group discussion, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(iii) Analyze the HHA's response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the HHA's emergency plan, as needed.

*[For OPOs at §486.360]
(d)(2) Testing. The OPO must conduct exercises to test the emergency plan. The OPO must do the following:
(i) Conduct a paper-based, tabletop exercise or workshop at least annually. A tabletop exercise is led by a facilitator and includes a group discussion, using a narrated, clinically relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan. If the OPO experiences an actual natural or man-made emergency that requires activation of the emergency plan, the OPO is exempt from engaging in its next required testing exercise following the onset of the emergency event.
(ii) Analyze the OPO's response to and maintain documentation of all tabletop exercises, and emergency events, and revise the [RNHCI's and OPO's] emergency plan, as needed.

*[ RNCHIs at §403.748]:
(d)(2) Testing. The RNHCI must conduct exercises to test the emergency plan. The RNHCI must do the following:
(i) Conduct a paper-based, tabletop exercise at least annually. A tabletop exercise is a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.
(ii) Analyze the RNHCI's response to and maintain documentation of all tabletop exercises, and emergency events, and revise the RNHCI's emergency plan, as needed.

Observations: Based on review of agency emergency preparedness documentation and interview with agency staff, the agency failed to document exercises to test the emergency plan annually, which includes a full-scale exercise that is community-based every 2 years and an additional exercise at least every 2 years, opposite the year of the full-scale exercise. Review of the agency emergency preparedness plan on February 10, 2026, at approximately 12:00 PM and February 17, 2026, at approximately 8:00 AM revealed no documentation of emergency preparedness exercises conducted annually. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has implemented a comprehensive emergency preparedness testing program in compliance with the regulations. Systems are now in place to ensure annual and biennial exercises are conducted, analyzed, documented, and used to revise the emergency plan as needed. Ongoing monitoring through the QAPI program will ensure sustainability and prevent recurrence.

All staff participated in an initial tabletop exercise on April 08, 2026, using a clinically-relevant emergency scenario. Roles, communication, patient safety procedures, and continuity of care were reviewed. Patient emergency information, care plans, and communication procedures were verified to ensure readiness in the event of an actual emergency. All exercises, including the tabletop exercise, were documented in the agency's emergency preparedness log.

All patient records were reviewed to confirm current emergency preparedness information and ensure any gaps were corrected. Any patient records with outdated or incomplete emergency information were updated immediately.

To prevent future deficiencies, the agency has implemented an emergency preparedness testing. All staff will participate in an annual emergency preparedness exercise. Emergency preparedness testing exercise, staff participation, outcomes, and plan updates will be documented.

The agency has established ongoing monitoring through its QAPI program. The Administrator will review exercise documentation quarterly to ensure compliance with annual and biennial requirements. Any staff not participating in required exercises will be scheduled for make-up sessions. Reports of exercises, analyses, and revisions will be reviewed in the agency's annual QAPI meeting to ensure continued compliance and improvement.





Initial Comments:Based on the findings of an unannounced onsite Medicare recertification survey initiated February 9, 2026 through February 10, 2026 and completed February 27, 2026 was found to not be in compliance with the requirements of 42 CFR, Part 484, Subparts B and C, Conditions of Participation: Home Health Agencies. As a result of the survey, three (3) condition level citation were issued at 484.55 (b) Comprehensive Assessments of Patients, 484.60 Care Planning, Coordination, Quality of Care, and 484.55 Quality Assessment/Performance Improvement but did not result in the identification of an immediate jeopardy. 
Plan of Correction:




484.55 CONDITION
Comprehensive Assessment of Patients

Name - Component - 00
Condition of participation: Comprehensive assessment of patients.
Each patient must receive, and an HHA must provide, a patient-specific, comprehensive assessment. For Medicare beneficiaries, the HHA must verify the patient's eligibility for the Medicare home health benefit including homebound status, both at the time of the initial assessment visit and at the time of the comprehensive assessment.

Observations: Based on review of agency policies/procedures, clinical records (CR), agency documents and an interview with the agency Administrator/Director of Nursing (PF#1) it was determined that the agency failed to ensure a registered nurse conducted the initial evaluation, completed a comprehensive assessment that included the patient's current health, psychosocial, functional, cognitive status, the patient's strengths, goals, and care preferences, the patient's continuing need for home care, the patient's medical, nursing, rehabilitative, social, and discharge planning needs, failed to review all medications, and updated the comprehensive assessment the last 5 days of every 60 days. This CONDITION is not met as evidenced under the following standards: Cross Reference: 484.55.(a)(1) (Tag 514): Initial assessment visit -failed to ensure a registered nurse conducted the initial assessment visit within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician or allowed practitioner - ordered start of care date for six (6) out of six (6) clinical records reviewed (CR#1-6 484.55(c)(1) (Tag 528): Content of comprehensive assessment-failed to ensure a registered nurse assessed the patient's current health, psychosocial, functional, and cognitive status for six (6) out of six (6) clinical record reviewed (CR#1-6) 484.55(c)(2) (Tag 530): The comprehensive assessment must accurately reflect the patient's strengths, goals, and care preferences-failed to ensure a registered nurse assessed the patient's strengths, goals, and care preferences for six (6) out of six (6) clinical record reviewed (CR#1-6) 484.55(c)(3) (Tag 532): The comprehensive assessment must include the patient's continuing need for home care-failed to ensure a registered nurse assessed the patient's continuing need for home care for six (6) out of six (6) clinical record reviewed (CR#1-6) 484.55(c)(4) (Tag 534): The comprehensive assessment must include the patient's medical, nursing, rehabilitative, social, and discharge planning needs.- failed to ensure a registered nurse assessed the patient's medical, nursing, rehabilitative, social, and discharge planning needs for six (6) out of six (6) clinical record reviewed (CR#1-6) 484.55(c)(5) (Tag 536): Review of all medications the patient is currently using to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy-failed to review of all medications the patient is currently using in order to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy for six (6) of the six (6) CRs reviewed. (CR#1-6) 484.55(d)(1) (Tag 546) Update of the comprehensive assessment the last 5 days of every 60 days beginning with the start-of-care date-failed to ensure a registered nurse updated the comprehensive assessment the last 5 days of every 60 days beginning with the star-of-care date for four (4) out of six (6) clinical record reviewed (CR#1, 2, 4, and 5) The cumulative effect of these systematic problems resulted in the agency's inability to ensure the provision of quality healthcare to the patients.

Plan of Correction:

Based on survey findings, the agency failed to ensure that a Registered Nurse (RN) conducted and documented the initial assessment, completed a comprehensive assessment including all required elements, reviewed medications, and updated the comprehensive assessment within the required timeframes. All patients identified in the survey sample were immediately reviewed by the Director of Nursing (DON).

The agency will conduct a 100% audit of all active and discharged patients for the previous 90 days to determine whether other patients were affected by the same deficient practice.
Any identified deficiencies will be corrected immediately by a Registered Nurse, and updated documentation will be placed in the patient's clinical record.
All clinical staff received mandatory re-education on the requirements, including timelines for SOC, ROC, and recertification, required components of the comprehensive assessment, and medication review standards. A standardized Start of Care and Recertification checklist was implemented to ensure all required elements of the comprehensive assessment are completed prior to submission.

On going thereafter: The agency incorporated monitoring of comprehensive assessment compliance into its Quality Assurance and Performance Improvement (QAPI) program. The Director of Nursing or designee will perform monthly audits of a minimum of 10% of active clinical records, including all new admissions for the first 60 days following implementation of this plan. Audit findings will be reviewed during quarterly QAPI meetings. Any identified trends or repeat deficiencies will result in additional staff training and corrective action.





484.55(a)(1) ELEMENT
RN performs assessment

Name - Component - 00
A registered nurse must conduct an initial assessment visit to determine the immediate care and support needs of the patient; and, for Medicare patients, to determine eligibility for the Medicare home health benefit, including homebound status. The initial assessment visit must be held either within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician or allowed practitioner - ordered start of care date.

Observations: Based upon reviews of agency policy/procedures, clinical records (CR) and an interview with the Administrator/Director of Nursing, it was determined the agency failed to ensure a registered nurse conducted the initial assessment visit within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician or allowed practitioner - ordered start of care date for six (6) out of six (6) clinical records reviewed (CR#1-6) Based upon clinical record review, agency policy review, and an interview with the Director of Nursing/Administrator and staff, it was determined the agency failed to ensure a registered nurse conducted the initial assessment visit within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician or allowed practitioner - ordered start of care date for six (6) out of six (6) clinical record reviewed (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "Admission Policy/Approved Treatments" stated, " 1. ADMISSIONS: Referrals are accepted by the Nursing Supervisor/designee on the Referral Form. C. ADMITTED TO CARE PROCESS: i. Once the determination is made that the patient is suitable for admission, an initial assessment is scheduled within 48 hours of the referral..." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. CR#2 SOC 6/29/2023: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. CR#3 SOC 1/20/2026: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. CR#4 SOC 2/4/2026: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. CR#5 SOC 11/24/2025: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. CR#6 SOC 4/23/2025: Contained no documentation of a referral form, a Plan of Care (POC), a certification period, or an initial or comprehensive assessment. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency failed to ensure that a Registered Nurse conducted the initial assessment visit within 48 hours of referral, within 48 hours of the patient's return home, or on the physician ordered Start of Care date for six (6) of six (6) clinical records reviewed.

All six clinical records cited in the survey findings were immediately reviewed by the Administrator/Director of Nursing. For patients who remained active, a Registered Nurse conducted a face-to-face comprehensive assessment and completed all required admission documentation, including referral verification, initial assessment, plan of care, and certification period documentation. For patients who were discharged, the records were reviewed to determine whether care had been appropriately delivered.

The agency conducted a 100% audit of all admissions for the previous 12 months to identify additional patients who may have been affected by the same deficient practice.

Any record found to be incomplete or missing required documentation was corrected by the Director of Nursing or assigned Registered Nurse.
The agency revised its admission workflow to ensure compliance with the federal requirement that an RN completes the initial assessment within 48 hours of referral or physician-ordered start of care date. The following system changes were implemented: A referral tracking log was implemented.

On going, the agency has incorporated monitoring of initial assessment timeliness into its Quality Assurance and Performance Improvement (QAPI) program. Monitoring activities include: Weekly review of all new admissions by the Director of Nursing for 90 days to verify RN assessment completion within required timeframes. Monthly audits of 10% of all admissions thereafter to ensure continued compliance. Tracking of compliance rates on a QAPI dashboard reviewed during quarterly QAPI meetings. Immediate corrective action and retraining for any staff member found to be out of compliance.


484.55(c)(4) ELEMENT
Patient's needs

Name - Component - 00
The patient's medical, nursing, rehabilitative, social, and discharge planning needs;

Observations: Based upon agency policy review, clinical record review(CR), and an interview with the Administrator/ Director of Nursing (PF#1), it was determined the agency failed to ensure a registered nurse assessed the patient's medical, nursing, rehabilitative, social, and discharge planning needs for six (6) out of six (6) clinical record reviewed (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "Assessments" stated, "a. THE COMPREHENSIVE ASSESSMENT MUST ACCURATELY REFELCTE THE PATIENT'S STATUS AND MUST INCLUDE: 9. Patient medical, nursing, rehab, social &; discharge planning needs." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. CR#2 SOC 6/29/2023: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. CR#3 SOC 1/20/2026: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. CR#4 SOC 2/4/2026: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. CR#5 SOC 11/24/2025: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. CR#6 SOC 4/23/2025: Contained no documentation of a comprehensive assessment that included the patient's medical, nursing, rehabilitative, social, and discharge planning needs. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency failed to ensure that the comprehensive assessment completed by a Registered Nurse included documentation of the patient's medical, nursing, rehabilitative, social, and discharge planning needs for six (6) of six (6) clinical records reviewed.

The agency conducted a 100% audit of all active and discharged patient records for the previous 90 days to determine whether other patients were affected by the same deficient practice. Any incomplete records identified during the audit were corrected by a Registered Nurse, and the comprehensive assessment and plan of care were updated accordingly. The agency implemented the following process changes: Admission and recertification workflows were updated to require supervisory review of the comprehensive assessment prior to finalization. All clinical staff received mandatory re-education on federal requirements and agency policy related to completion of the comprehensive assessment.

On going, compliance with comprehensive assessment requirements has been incorporated into the agency's Quality Assurance and Performance Improvement (QAPI) program. The Director of Nursing or designee will conduct audits of 100% of Start of Care assessments for 60 days, followed by monthly audits of at least 10% of active records. Audits will verify that all required patient needs are assessed and documented and that identified needs are reflected in the plan of care. Audit findings will be reviewed during quarterly QAPI meetings. Any identified trends or repeat deficiencies will result in immediate corrective action and additional staff training.


484.60 CONDITION
Care planning, coordination, quality of care

Name - Component - 00
Condition of participation: Care planning, coordination of services, and quality of care.
Patients are accepted for treatment on the reasonable expectation that an HHA can meet the patient's medical, nursing, rehabilitative, and social needs in his or her place of residence. Each patient must receive an individualized written plan of care, including any revisions or additions. The individualized plan of care must specify the care and services necessary to meet the patient-specific needs as identified in the comprehensive assessment, including identification of the responsible discipline(s), and the measurable outcomes that the HHA anticipates will occur as a result of implementing and coordinating the plan of care. The individualized plan of care must also specify the patient and caregiver education and training. Services must be furnished in accordance with accepted standards of practice.

Observations: Based on review of agency policies/procedures, clinical records (CR), and an interview with the agency's Administrator/Director of Nursing(PF#1), it was determined that the agency failed to ensure individualized care plans were developed (Tag 572);individualized to meet the patient's needs and cover all the required elements (tag 574); ordered and signed by a physician (Tag 580); reviewed and revised at least every sixty 60 days (Tag 592) for six (6) of six (6) records reviewed CR #1-6; This CONDITION is not met as evidenced under the following standards: Cross Reference: 484.60(a)(1) (Tag 572): Plan of care- failed to ensure a Home Health Certification and Plan of Care/Treatment was created for six (6) out of six (6) clinical record reviewed (CR#1-6) 484.60(a)(2) (Tag 574): Content of the plan of care- failed to ensure an individualized plan of care was developed that covered all required elements per agency policy for six (6) of six (6) clinical records (CR) reviewed. (CR #1-6) 484.60(b) (Tag 580) Conformance with the physician orders- failed to obtain a physician order for services, and treatments and/or medications for six (6) of the six (6) CRs reviewed. (CR#1-6) 484.60(d) (Tag 588) Review and revision of the plan of care- failed to ensure an individualized plan of care was reviewed and revised no less frequently than every 60 days for six (6) of six (6) clinical records (CR) reviewed. (CR #1-6) 484.60(c)(2) (Tag 592) Revised plan of care reflects information in updated comprehensive assessment- failed to ensure a revised plan of care reflecting current information from the updated comprehensive assessment contained information regarding the patient's progress toward measurable outcomes and goals for six (6) of six (CR) reviewed. (CR #1-6) The cumulative effect of these systematic problems resulted in the agency's inability to ensure the provision of quality healthcare to the patients.

Plan of Correction:

All six clinical records cited were immediately reviewed by the Administrator/Director of Nursing (DON). For each affected patient: A comprehensive assessment was reviewed or completed by a Registered Nurse. An individualized Home Health Certification and Plan of Care (POC) was developed based on the patient's current clinical status and identified needs. Plans of care were updated to include measurable goals, responsible disciplines, frequency of visits, medications, treatments, and patient/caregiver education. The revised plans of care were submitted to the attending physicians for review, signature, and certification. For active patients, services were aligned immediately with the updated physician-signed plan of care.

All six clinical records cited were immediately reviewed by the Administrator/Director of Nursing (DON). For each affected patient: A comprehensive assessment was reviewed or completed by a Registered Nurse. An individualized Home Health Certification and Plan of Care (POC) was developed based on the patient's current clinical status and identified needs. Plans of care were updated to include measurable goals, responsible disciplines, frequency of visits, medications, treatments, and patient/caregiver education. The revised plans of care were submitted to the attending physicians for review, signature, and certification. For active patients, services were aligned immediately with the updated physician-signed plan of care.

To ensure compliance comprehensive assessment will be reviewed within 5 days of the star of care date to ensure they include measurable goals and expected outcomes, responsible disciplines, medication and treatment orders, patient and caregiver education. A POC tracking log will be created to monitor: date of certification period start and end, Physician signature status, due dates for 60-day recertification and plan revisions. A physician signature tracking, and timely review of the plan of care was created to ensure POC are signed per policy. All clinical staff received mandatory re-education on federal care planning requirements and agency documentation standards.

On going, the agency has incorporated monitoring of initial assessment timeliness into its Quality Assurance and Performance Improvement (QAPI) program. Monitoring activities include: 100% review of all new admissions and recertifications for 90 days to ensure compliance with the requirements. After 90 days, the agency will conduct monthly audits of 10% of active clinical records. Audit results will be presented during quarterly QAPI meetings and trended to identify patterns or staff training needs. Any identified deficiencies will result in immediate corrective action, documentation correction, and staff retraining.



484.60(a)(1) STANDARD
Plan of care

Name - Component - 00
Each patient must receive the home health services that are written in an individualized plan of care that identifies patient-specific measurable outcomes and goals, and which is established, periodically reviewed, and signed by a doctor of medicine, osteopathy, or podiatry acting within the scope of his or her state license, certification, or registration. If a physician or allowed practitioner refers a patient under a plan of care that cannot be completed until after an evaluation visit, the physician or allowed practitioner is consulted to approve additions or modifications to the original plan.

Observations: Based upon agency policy review, clinical record(CR) review, and an interview with the Administrator/Director of Nursing, it was determined the agency failed to ensure a Home Health Certification and Plan of Care/Treatment was created for six (6) out of six (6) clinical record reviewed (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 11:30 AM and revealed the following: Agency policy titled "Plan of Care (POC)" stated, " Policy: Each patient will receive home health services that are written in an individual plan of care that identifies patient-specific measurable outcomes and goals, which is established, periodically reviewed and signed by a physician...2. POC development: The POC is: b. Developed within 5 days of the SOC/ROC or Follow UP Assessment...g. Must be signed by the attending...p Administrator/Clinical Manager or Nursing Supervisor shall review the plan of care for completeness prior to it being submitted to MD for signature...r. A copy of the POC shall be maintained in the patient's clinical record...3. POC UPDATES/REVISIONS: A revised POC must reflect current information from the patients updated comprehensive assessment...a. The POC is updated/revised: i. At least every 60 days beginning with the SOC date. ii. Upon initial assessment and development of the 485. iii. As new orders are received. vi. At Follow Up Recertification periods...b. Update process: At time of recertification, a written summary of the patient's status and the services being provided, is submitted with the POC for physician review... 4. POC INCLUDES All pertinent diagnosisb. Patients mental, Psychosocial, and cognitive status c. Types of services, supplies, and equipment needs. d. Frequency &; duration of visits of be made e. Prognosis, f. Rehab Potential g. Functional Limitations h. Activities permitted i. Nutritional requirements j. All medications and treatments k. Safety measures to protect against injury..." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:00 A.M to 1:00 PM, and again on February 10, 2026, at approximately 1PM which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items.File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 12/7/2023, admission diagnosis Autistic disorder, primary diagnosis Autistic disorder, secondary diagnosis pervasive developmental disorder unspecified. The Calendar revealed HHA visits Monday - Friday from 7 am -4 pm, then 8:30 pm -4:30 am. Saturday and Sunday 7 am -2 pm, then 8:30 pm-4:30 am. CR#2 SOC 6/29/2023: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 6/29/2023, admission diagnosis Cerebral Palsy, unspecified, primary diagnosis oth generalized epilepsy, not intractable, w stat epi, secondary diagnosis cortical blindness, right side of brain. The Calendar revealed LPN visits started on June 30, 2023. From September 5, 2025, to February 7, 2026, 1-5 times a week from 8pm to 7am. CR#3 SOC 1/27/2026: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 1/20/2026, admission diagnosis Down syndrome, unspecified. The Calendar revealed HHA visit started on 2/3/26, from 9am to 12pm. CR#4 SOC 2/4/2026: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 1/26/2026, admission diagnosis Unspecified convulsions, secondary diagnosis Epileptic spasms, intractable, with status epilepticus. The Calendar revealed HHA visit started on 2/8/26 from 12pm-8pm, Monday to Friday from 3pm-11pm, and Sunday from 12pm to 8pm. CR#5 SOC 11/24/2025: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 11/24/2025, admission diagnosis Congenital hypotonia, primary diagnosis, Congenital hypotonia, secondary diagnosis Congenital hypotonia, and services required Home Health Aide. The Calendar revealed HHA visit started on November 25, 2025. Monday to Sunday from 2pm to 10pm, then 10:00 pm to 6am. CR#6 SOC 4/23/2025: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 4/23/2025, admission diagnosis Autistic disorder, Primary diagnosis Autistic disorder, secondary diagnosis Mixed receptive-expressive language disorder, and services required Home Health Aide. The Calendar revealed HHA visit started on 8/1/2025 from 9:30 am-3:30 pm. Visits times documented as follows: Monday, Tuesday Saturday and Sunday from 9:30 AM to 3:30 PM, Wednesday, Thursday and Friday 9:30 am to 3:30 pm and 5:30 pm to 9:30 pm. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

All six clinical records cited were immediately reviewed by the Administrator/Director of Nursing (DON). A Registered Nurse completed a comprehensive assessment or reviewed the most recent assessment to ensure it reflected the patient's current clinical status. A Home Health Certification and Plan of Care (Form 485) was developed for each patient, incorporating all required elements including diagnoses, functional limitations, mental and psychosocial status, medications, treatments, frequency and duration of visits, safety measures, and measurable goals. The plans of care were submitted to the attending physicians for review, signature, and certification. Services were aligned with physician orders once plans of care were signed, and documentation was updated to accurately reflect care provided.

The agency will conduct a 100% audit of all active and discharged patient records for the previous 12 months to identify any additional cases where a Home Health Certification and Plan of Care are missing, incomplete, or unsigned. Any additional records identified with missing or incomplete plans of care will be corrected immediately. New plans of care will be generated and submitted to physicians for signature and certification.
The agency implemented the following corrective system changes to ensure that all patients receive services under an individualized, physician-signed plan of care: A Plan of Care tracking log was implemented to monitor Inclusion of all required plan elements per agency policy and federal regulation. All clinical and administrative staff involved in admissions, scheduling, and documentation were provided mandatory re-education on federal plan of care requirements and agency policy.

The agency incorporated compliance monitoring into its Quality Assurance and Performance Improvement (QAPI) program. Monitoring activities include: 100% review of all new admissions and recertifications for 90 days to verify that a plan of care is developed, completed, and submitted to the physician within required timeframes. Monthly audits of at least 10% of clinical records thereafter to verify continued compliance with plan of care requirements. The Director of Nursing will track physician signature turnaround times and follow up with providers as needed. Audit findings and compliance trends will be reviewed during quarterly QAPI meetings, and corrective actions will be implemented if deficiencies are identified.



484.60(a)(2)(i-xvi) ELEMENT
Plan of care must include the following

Name - Component - 00
The individualized plan of care must include the following:
(i) All pertinent diagnoses;
(ii) The patient's mental, psychosocial, and cognitive status;
(iii) The types of services, supplies, and equipment required;
(iv) The frequency and duration of visits to be made;
(v) Prognosis;
(vi) Rehabilitation potential;
(vii) Functional limitations;
(viii) Activities permitted;
(ix) Nutritional requirements;
(x) All medications and treatments;
(xi) Safety measures to protect against injury;
(xii) A description of the patient's risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors.
(xiii) Patient and caregiver education and training to facilitate timely discharge;
(xiv) Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient;
(xv) Information related to any advanced directives; and
(xvi) Any additional items the HHA or physician or allowed practitioner may choose to include.

Observations: Based on a review of agency policy, review of clinical records, and an interview with the agency Administrator/Director of Nursing (PF#1), the agency failed to ensure an individualized plan of care was developed that covered all required elements per agency policy for six (6) of six (6) clinical records (CR) reviewed. (CR #1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy #C: 48 titled "Plan of care (POC) stated, "4. POC INCLUDES: The POC is developed in consultation with staff, patient, physician and other providers involved in the patient's care and includes: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, l. Plans for the patient during a natural or man-made disaster, m. A description of the patient's risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors, n. Patient &; caregiver education/training to facilitate timely discharge, o. Patient specific interventions &; education, p. Measurable outcomes &; goals identified by the patient &; Agency, q. Information related to any Advance Directives, r. Homebound status, s. Any additional items the Agency or physician may choose to include." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a Plan of Care (POC) or orders on file. CR#2 SOC 6/29/2023: Contained no documentation of a Plan of Care (POC) or orders on file. CR#3 SOC 1/20/2026: Contained no documentation of a Plan of Care (POC) or orders on file. CR#4 SOC 2/4/2026: Contained no documentation of a Plan of Care (POC) or orders on file. CR#5 SOC 11/24/2025: Contained no documentation of a Plan of Care (POC) or orders on file. CR#6 SOC 4/23/2025: Contained no documentation of a Plan of Care (POC) or orders on file. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

All six clinical records cited in the survey findings will be reviewed by the Administrator/Director of Nursing (DON) to ensure all current patient needs were identified. A complete and individualized Home Health Certification and Plan of Care will be developed and updated to include all required elements under federal regulation, including diagnoses, functional limitations, mental and psychosocial status, medications, treatments, safety measures, measurable goals, discharge planning, emergency preparedness planning, and patient/caregiver education. The plans of care were submitted to the attending physicians for review, approval, and signature. Services were reviewed and aligned with the updated physician-approved plan of care to ensure care was delivered in accordance with documented patient needs.

The agency will conduct a 100% audit of all active and recently discharged patient records for the previous 12 months to identify any additional patients whose plans of care did not contain all required elements. Any records found to be incomplete will be corrected by updating the plan of care and obtaining physician signature where required.

To prevent recurrence, A Plan of Care tracking log was implemented to monitor Inclusion of all required plan elements per agency policy and federal regulation. All clinical and administrative staff involved in admissions, scheduling, and documentation were provided mandatory re-education on federal plan of care requirements and agency policy.

On going, the agency has incorporated compliance with plan of care content requirements into its Quality Assurance and Performance Improvement (QAPI) program. Monitoring activities include: 100% review of all newly created plans of care for 90 days by the Director of Nursing or designee. Monthly audits of at least 10% of active clinical records thereafter to ensure that all required plan elements are consistently documented. Audit findings will be tracked and trended and reviewed during quarterly QAPI meetings to identify patterns and implement corrective actions when needed. Staff found to be noncompliant will receive immediate re-education and follow-up audits to ensure improvement.



484.60(b)(1) ELEMENT
Only as ordered by a physician

Name - Component - 00
Drugs, services, and treatments are administered only as ordered by a physician or allowed practitioner.

Observations: Based upon agency policy review, clinical record (CR) review, and an interview with the Administrator/Director of Nursing (PF#1), it was determined the agency failed to obtain a physician order for services, and treatments and/or medications for six (6) of the six (6) CRs reviewed. (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled " Physician Services" stated, "POLICY: Drugs, services and treatments are administered by Agency staff only as ordered by a physicianreview of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: A document titled "Client Profile" revealed a SOC of 12/7/2023, admission diagnosis Autistic disorder, primary diagnosis Autistic disorder, secondary diagnosis pervasive developmental disorder unspecified. The Calendar revealed HHA visits Monday - Friday from 7 am -4 pm, then 8:30 pm -4:30 am. Saturday and Sunday 7 am -2 pm, then 8:30 pm-4:30 am. Contained no evidence of a physician order. CR#2 SOC 6/29/2023: A document titled "Client Profile" revealed a SOC of 6/29/2023, admission diagnosis Cerebral Palsy, unspecified, primary diagnosis oth generalized epilepsy, not intractable, w stat epi, secondary diagnosis cortical blindness, right side of brain, and services required Skilled Nurse. The Calendar revealed LPN visits 1-5 times a week from September 5, 2025, to February 7, 2026. Nurses note dated 1/10/2026, the LPN documented administering "all medication, feedings, and fluids " via G-tube. LPN documented on 1/11/26 "formula Compleat Pediatric @55ml/hr for a total volume of 450ml." LPN note dated 1/18/26, the LPN documented, "All medications, feedings, and fluids administered as ordered, well tolerated." Nurses note dated 1/24/2026, the LPN documented "saline drops administered to nostrils, rub chest ointment applied to the patient's chest per Dad request." Contained no evidence of a physician order. Contained no medication list or record. CR#3 SOC 1/20/2026: A document titled "Client Profile" revealed a SOC of 1/20/2026, admission diagnosis Down syndrome, unspecified, and services required Home Health Aide. The Calendar revealed HHA visit started on 2/3/26 from 9am to 12pm. Contained no evidence of a physician order. CR#4 SOC 2/4/2026: A document titled "Client Profile" revealed a SOC of 1/26/2026, admission diagnosis Unspecified convulsions, secondary diagnosis Epileptic spasms, intractable, with status epilepticus, and services required Home Health Aide. The Calendar revealed HHA visit started on 2/8/26 from 12pm-8pm. Contained no evidence of a physician order. CR#5 SOC 11/24/2025: A document titled "Client Profile" revealed a SOC of 11/24/2025, admission diagnosis Congenital hypotonia, primary diagnosis, Congenital hypotonia, secondary diagnosis Congenital hypotonia, and services required Home Health Aide. The Calendar revealed HHA visit started on 11/25/2025 from 2pm to 10pm, then 10om to 6am. Contained no evidence of a physician order. CR#6 SOC 4/23/2025: A document titled "Client Profile" revealed, SOC of 4/23/2025, admission diagnosis Autistic disorder, Primary diagnosis Autistic disorder, secondary diagnosis Mixed receptive-expressive language disorder, and services required Home Health Aide. The Calendar revealed HHA visit started on 8/1/2025 from 9:30 am-3:30 pm. Visits times documented as follows: Monday, Tuesday Saturday and Sunday from 9:30 AM to 3:30 PM, Wednesday, Thursday and Friday 9:30 am to 3:30 pm and 5:30 pm to 9:30 pm. Contained no evidence of a physician order. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

All six clinical records cited will be immediately reviewed by the Administrator/Director of Nursing (DON). For each affected patient: The attending physicians will be contacted to obtain written orders authorizing all services, medications, and treatments that had been provided. A comprehensive review of each patient's medications, treatments, and services was conducted by a Registered Nurse to ensure they were appropriate and consistent with physician direction. Physician orders will be obtained and placed in the clinical record, and care plans will be updated to reflect these orders.

the agency will conduct a 100% audit of all active and discharged patient records for the previous 12 months to determine whether additional patients were affected by the same deficient practice. Any records identified as lacking physician authorization will be corrected by obtaining appropriate written orders and updating the clinical documentation.
To prevent recurrence: the agency will ensure that no patient is admitted or scheduled for services until physician orders are received and verified by the clinical supervisor. A Physician Order Verification log has been created to confirm that all services, medications, and treatments are authorized prior to the start of care. All nursing and administrative staff received mandatory re-education on this requirement and agency policy.

Compliance with physician order requirements has been incorporated into the agency's Quality Assurance and Performance Improvement (QAPI) program. Monitoring activities include: 100% review of all new admissions and physician orders for 90 days to verify that services are not initiated until orders are received. Monthly audits of at least 10% of clinical records thereafter to confirm that all documented services and treatments are supported by physician orders. The Director of Nursing will maintain a log tracking outstanding physician orders and follow up with providers until all orders are signed and returned. Audit findings will be reviewed during quarterly QAPI meetings and trended for ongoing compliance.


484.60(c)(1) ELEMENT
Reviewed, revised by physician every 60 days

Name - Component - 00
The individualized plan of care must be reviewed and revised by the physician or allowed practitioner who is responsible for the home health plan of care and the HHA as frequently as the patient's condition or needs require, but no less frequently than once every 60 days, beginning with the start of care date.

Observations: Based on a review of agency policy, review of clinical records, and an interview with the agency Administrator/Director of Nursing (PF#1), the agency failed to ensure an individualized plan of care was reviewed and revised no less frequently than every 60 days for six (6) of six (6) clinical records (CR) reviewed. (CR #1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy #C: 48 titled "Plan of care (POC) stated, "3. POC UPDATES/REVISIONS:A revised POC must reflect current information from the patient's updated comprehensive assessment and contain info from the patient's progress towards measurable outcomes &; goals identified by the Agency &; patient in the POC. a. The POC is updated/revised: i. At least every 60 days beginning with the SOC date." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a Plan of Care (POC) or orders on file. CR#2 SOC 6/29/2023: Contained no documentation of a Plan of Care (POC) or orders on file. CR#3 SOC 1/20/2026: Contained no documentation of a Plan of Care (POC) or orders on file. CR#4 SOC 2/4/2026: Contained no documentation of a Plan of Care (POC) or orders on file. CR#5 SOC 11/24/2025: Contained no documentation of a Plan of Care (POC) or orders on file. CR#6 SOC 4/23/2025: Contained no documentation of a Plan of Care (POC) or orders on file. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

All six cited clinical records will be immediately reviewed by the Administrator/Director of Nursing (DON). The Director of Nursing will ensure that each affected patient has a developed and completed individualized Plans of Care (POCs) based on the most recent comprehensive assessment. The DON will Contact the responsible physicians to obtain review, revision, and signatures for each patient's POC. Ensured that all POCs reflected current patient status, measurable goals, interventions, and services being provided. Documented physician approval and placed signed POCs in the clinical record.

The agency will conduct a 100% audit of all active and discharged patient records for the previous 12 months to identify any additional patients affected by the same deficient practice. Any records identified without timely physician-reviewed POCs will be corrected.
To prevent recurrence: the agency implemented A Plan of Care tracking log was implemented to monitor POC due dates beginning from the Start of Care date and every 60 days thereafter. The agency re-educated all clinical and administrative staff on agency Policy.

To ensure ongoing compliance, the agency incorporated POC review and revision monitoring into its Quality Assurance and Performance Improvement (QAPI) program: 100% review of all new admissions and recertifications for 90 days to ensure POCs are developed and reviewed within required timeframes. Monthly audits of 10% of active clinical records thereafter to verify continued compliance with 60-day review requirements. The Director of Nursing will review the POC tracking log weekly to ensure no recertification or revision deadlines are missed. Audit results will be presented during quarterly QAPI meetings and trended to identify any patterns or areas needing additional training. Monitoring will remain in place until sustained compliance is demonstrated for two consecutive quarters.


484.60(c)(2) ELEMENT
Revised plan of care

Name - Component - 00
A revised plan of care must reflect current information from the patient's updated comprehensive assessment, and contain information concerning the patient's progress toward the measurable outcomes and goals identified by the HHA and patient in the plan of care.

Observations: Based on a review of agency policy, review of clinical records, and an interview with the agency Administrator/Director of Nursing (PF#1), the agency failed to ensure a revised plan of care reflecting current information from the updated comprehensive assessment contained information regarding the patient's progress toward measurable outcomes and goals for six (6) of six (CR) reviewed. (CR #1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy #C: 48 titled "Plan of care (POC) stated, "3. POC UPDATES/REVISIONS:A revised POC must reflect current information from the patient's updated comprehensive assessment and contain info from the patient's progress towards measurable outcomes &; goals identified by the Agency &; patient in the POC." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. CR#2 SOC 6/29/2023: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. CR#3 SOC 1/20/2026: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. CR#4 SOC 2/4/2026: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. CR#5 SOC 11/24/2025: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. CR#6 SOC 4/23/2025: Contained no documentation of a comprehensive assessment or a Plan of Care (POC) containing information regarding the patient's progress toward measurable outcomes and goals. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

All six cited clinical records will be immediately reviewed by the Administrator/Director of Nursing (DON) to ensure that there is Completed comprehensive assessments for all affected patients with current clinical status. Affected patient POC will be developed and/or revised to reflect: Updated patient assessments, measurable goals and outcomes, documentation of patient progress toward those goals. Al revised POCs will be submitted to the attending physicians for review, approval, and signature.


The agency conducted a 100% audit of all active and discharged records for the previous 12 months. To identify additional patients who may have been affected. Any record found to be missing this information was corrected by completing updated assessments and revising the plan of care accordingly, followed by physician review and signature.

To prevent recurrence, the agency implemented Plan of Care Revision Template to ensure all requirements are documented in the POC. All clinical staff received retraining on requirements for comprehensive assessments, documentation of patient progress, alignment between assessments, goals, and interventions.

To ensure compliance, the agency incorporated these elements into its Quality Assurance and Performance Improvement (QAPI) program: 100% review of all reassessments and recertification packets for 90 days to ensure revised POCs reflect updated patient information and progress toward goals. Monthly audits of at least 10% of clinical records. Audit findings are documented and reviewed during quarterly QAPI meetings, and any deficiencies will result in immediate corrective staff education and follow-up audits. Monitoring will continue until compliance is demonstrated for two consecutive quarters.


484.65 CONDITION
Quality assessment/performance improvement

Name - Component - 00
Condition of participation: Quality assessment and performance improvement (QAPI).

The HHA must develop, implement, evaluate, and maintain an effective, ongoing, HHA-wide, data-driven QAPI program. The HHA's governing body must ensure that the program reflects the complexity of its organization and services; involves all HHA services (including those services provided under contract or arrangement); focuses on indicators related to improved outcomes, including the use of emergent care services, hospital admissions and re-admissions; and takes actions that address the HHA's performance across the spectrum of care, including the prevention and reduction of medical errors. The HHA must maintain documentary evidence of its QAPI program and be able to demonstrate its operation to CMS.

Observations: Based on review of agency policies/procedures, clinical records (CR), and an interview with the agency Administrator/Director of Nursing (PF#1), the agency failed to ensure development of a Quality Assessment and Performance Improvement (QAPI) program that showed measurable outcomes indicators that would improve health outcomes, patient safety and quality of care by measuring, analyzing, and tracking quality indicators (Tag 642); failed to ensure performance activities focused on high risk, high volume, and problem prone areas (Tag 656); failed to conduct performance improvement projects (Tag 658) for one (1) of one (1) year received. 2025. This CONDITION is not met as evidenced under the following standards: Cross Reference: 484.65(a) (Tag 642): Program scope-failed to develop a Quality Assessment and Performance Improvement (QAPI) program that showed measurable improvement in indicators that would improve health outcomes, patient safety and quality of care by measuring, analyzing, and tracking quality of indicators for one (1) of one (1) QAPI requested. 484.65(c) (Tag 646): Program activities- agency failed to develop a Quality Assessment and Performance Improvement (QAPI) program that contained performance improvement activities focused on high risk, high volume, or problem-prone areas for one (1) of one (1) QAPI requested. 484.65(c)(3) (Tag 656) Implementation- failed to develop a Quality Assessment and Performance Improvement (QAPI) program that contained performance improvement activities focused on high risk, high volume, or problem-prone areas for one (1) of one (1) QAPI requested. 484.66(d) (Tag 658) Performance improvement projects- failed to conduct performance improvement projects as part of the Quality Improvement Performance Improvement (QAPI) program for one (1) of one (1) QAPI requested. The cumulative effect of these systematic problems resulted in the agency's inability to ensure the provision of quality healthcare to the patients.

Plan of Correction:

The agency acknowledges that its QAPI program did not demonstrate measurable outcomes, performance improvement activities, or performance improvement projects for calendar year 2025. The agency has taken immediate action to develop and implement a comprehensive, data-driven, agency-wide QAPI program.
The lack of an effective QAPI program placed all patients at risk for potential quality and safety issues. The Administrator and Director of Nursing conducted a clinical review of all active patients to verify compliance. Any identified clinical documentation or care coordination deficiencies were corrected immediately.

Because the deficient practice involved the absence of a functioning agency-wide QAPI program, all patients served during 2025 and current active patients were considered potentially affected. The agency performed: a retrospective review any trends or quality concerns identified during the review will be addressed through immediate corrective clinical interventions and documentation updates.

The agency has fully developed and implemented a structured Quality Assessment and Performance Improvement (QAPI) Program that includes: Governing Body Oversight.

The agency initiated its first formal Performance Improvement Plan. A standardized QAPI data collection tool was implemented. Quality data will be collected monthly and trended over time to identify performance patterns.
To ensure the QAPI program remains active and effective: Monthly QAPI meetings will be conducted with participation from administration, nursing, and contracted services. Meeting minutes, data reports, and action plans will be maintained as evidence. The agency will maintain documentation demonstrating the operation and effectiveness of the QAPI program and will present this documentation during any future surveys.



484.65(a)(1),(2) STANDARD
Program scope

Name - Component - 00
Standard: Program scope.
(1) The program must at least be capable of showing measurable improvement in indicators for which there is evidence that improvement in those indicators will improve health outcomes, patient safety, and quality of care.

(2) The HHA must measure, analyze, and track quality indicators, including adverse patient events, and other aspects of performance that enable the HHA to assess processes of care, HHA services, and operations.

Observations: Based upon agency policy/procedures review and an interview with the Director of Nursing/Administrator (PF#1), it was determined the agency failed to develop a Quality Assessment and Performance Improvement (QAPI) program that showed measurable improvement in indicators that would improve health outcomes, patient safety and quality of care by measuring, analyzing, and tracking quality of indicators for one (1) of one (1) QAPI requested. Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "A: 24 Quality Assessment Performance Improvement (QAPI) IC Committee" states, "POLICY: Our Agency believes in fostering ongoing improvement of the organization's performance and quality of services &; programs through its Quality Assessment Performance Improvement (QAPI) program. See QAPI Policy Binder for complete QA program policies and procedurespolicy titled "QA: 1 QAPI Policy" states, "POLICY: It is the policy of our Agency to have in place, an ongoing quality assurance and performance improvement (QAPI) program that is agency-wide, data-driven, across all aspects of Agency services and programsQAPI program documentation was requested on February 9, 2026, at approximately 11:30 AM. The agency Administrator/Director of Nursing could not provide any documentation pertaining to the QAPI program. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that it did not maintain documentation demonstrating an active, data-driven QAPI program capable of measuring, analyzing, and tracking quality indicators or demonstrating measurable improvement in patient outcomes, safety, and quality of care.
The Administrator/Director of Nursing conducted a review of all active patient records to verify compliance.

Because the deficiency involved the lack of a functioning QAPI program, all patients served within the last 12 months were considered potentially affected. The agency therefore: Conducted a retrospective review. Any trends or quality concerns identified during the review will be addressed through immediate corrective clinical interventions and documentation updates.
The agency developed and implemented a fully structured, documented, and data-driven Quality Assessment and Performance Improvement (QAPI) Program to meet regulatory requirements.

The agency implemented a tracking tools to ensure ongoing collection and trending of quality data. Data is now compiled monthly and analyzed to identify opportunities for improvement. All administrative and clinical staff received training on QAPI.

To ensure that the QAPI program remains active and effective: Monthly QAPI committee meetings will be conducted to review quality indicator data and identify trends. Meeting minutes, data reports, and action plans are maintained as documentary evidence. The Administrator ensures that quality indicators are measured, analyzed, and trended monthly, and that any negative trends result in corrective action plans or performance improvement projects (PIPs).


484.65(c) STANDARD
Program activities

Name - Component - 00
(1) The HHA's performance improvement activities must—
(i) Focus on high risk, high volume, or problem-prone areas;
(ii) Consider incidence, prevalence, and severity of problems in those areas; and
(iii) Lead to an immediate correction of any identified problem that directly or
potentially threaten the health and safety of patients.

Observations: Based upon agency policy/procedure review and an interview with the Administrator/Director of Nursing (PF#1), it was determined the agency failed to develop a Quality Assessment and Performance Improvement (QAPI) program that contained performance improvement activities focused on high risk, high volume, or problem-prone areas for one (1) of one (1) QAPI requested. Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "QA: 4 QA Performance Improvement Projects (PIPs)" states, "PROCEDURE: A Performance Improvement Project (PIP) is a concentrated effort on a particular problem in one area of the agency or agency wide; it involves gathering information systematically to clarify issues or problems and intervening for improvements. The agency conducts PIPs to examine and improve care/services in areas that the agency identifies as needing attention. Areas that need attention will vary depending on the agency and the unique scope of services the agency provides. Our Agency will prioritize PIPs as follows: Areas that affect patients first, High risk areas for opportunities and improvementOur agency will document: All QA projects undertaken, The reasons for conducting these projects, The measurable progress achieved on the projects." The QAPI program documentation was requested on February 9, 2026, at approximately 11:30 AM. The agency Administrator/Director of Nursing could not provide any documentation pertaining to the QAPI program. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

Although no immediate patient harm was identified during the survey, the absence of performance improvement activities placed patients at risk for unmonitored quality and safety concerns.

The agency acknowledges that it did not maintain documentation demonstrating that performance improvement activities were conducted or focused on high-risk, high-volume, or problem-prone areas as required. The agency has developed and implemented a structured process to identify, prioritize, and address performance improvement activities in accordance with federal requirements.
The Administrator/Director of Nursing conducted a review of all active patient records to identify any current clinical or safety concerns. Any issues identified during the review were corrected.

All patients served within the past 12 months were considered potentially affected. The agency conducted a retrospective review for compliance. To prevent recurrence the agency established criteria to identify performance improvement priorities.

To ensure ongoing compliance and sustained improvement: The agency conducts monthly QAPI meetings to review performance data and evaluate progress of active PIPs. Data related to identified high-risk areas is collected and analyzed monthly.

The Director of Nursing maintains documentation of all PIP activities, including meeting minutes, data analysis, corrective actions, and progress toward improvement goals.
Any performance issue that poses an immediate threat to patient health or safety will be corrected immediately, and the event will be reviewed during the next QAPI meeting to determine whether additional system changes are required.




484.65(c)(3) ELEMENT
Improvements are sustained

Name - Component - 00
The HHA must take actions aimed at performance improvement, and, after implementing those actions, the HHA must measure its success and track performance to ensure that improvements are sustained.

Observations: Based upon agency policy/procedure review and an interview with the Administrator/Director of Nursing (PFF#1), it was determined the agency failed to develop a Quality Assessment and Performance Improvement (QAPI) program that contained performance improvement activities focused on high risk, high volume, or problem-prone areas for one (1) of one (1) QAPI requested. Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "QA: 4 QA Performance Improvement Projects (PIPs)" states, "PROCEDURE: A Performance Improvement Project (PIP) is a concentrated effort on a particular problem in one area of the agency or agency wide; it involves gathering information systematically to clarify issues or problems and intervening for improvements. The agency conducts PIPs to examine and improve care/services in areas that the agency identifies as needing attention. Areas that need attention will vary depending on the agency and the unique scope of services the agency provides. Our Agency will prioritize PIPs as follows: Areas that affect patients first, High risk areas for opportunities and improvementOur agency will document: All QA projects undertaken, The reasons for conducting these projects, The measurable progress achieved on the projects." The QAPI program documentation was requested on February 9, 2026, at approximately 11:30 AM. The agency Administrator/Director of Nursing could not provide any documentation pertaining to the QAPI program. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that it did not demonstrate that performance improvement activities were tracked and monitored to ensure sustained improvements. The agency has implemented a corrective action plan to ensure that improvements are identified, implemented, and monitored for sustainability. The Director of nursing will review of all active patient records to identify any care gaps, missed interventions, or unmet needs.

All patients active in the past 12 months were considered potentially affected. The agency performed a retrospective review all gaps were addressed immediately with updated care plans, staff notifications, and physician communication.

All staff educated on QAPI requirements, importance of sustaining improvements, and their role in monitoring and reporting outcomes.

To ensure ongoing compliance and sustained improvement: The agency conducts monthly QAPI meetings to review performance data and evaluate progress of active PIPs. Monitoring is ongoing and will continue indefinitely as part of the agency's QAPI program.





484.65(d)(1)(2) STANDARD
Performance improvement projects

Name - Component - 00
Standard: Performance improvement projects.
Beginning July 13, 2018 HHAs must conduct performance improvement projects.

(1) The number and scope of distinct improvement projects conducted annually must reflect the scope, complexity, and past performance of the HHA's services and operations.

(2) The HHA must document the quality improvement projects undertaken, the reasons for conducting these projects, and the measurable progress achieved on these projects.

Observations: Based upon agency policy/procedure review and an interview with the Administrator/Director of Nursing (PF#1), it was determined the agency failed to conduct performance improvement projects as part of the Quality Improvement Performance Improvement (QAPI) program for one (1) of one (1) QAPI requested. Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled "QA: 4 QA Performance Improvement Projects (PIPs)" states, "PROCEDURE: A Performance Improvement Project (PIP) is a concentrated effort on a particular problem in one area of the agency or agency wide; it involves gathering information systematically to clarify issues or problems and intervening for improvements. The agency conducts PIPs to examine and improve care/services in areas that the agency identifies as needing attention. Areas that need attention will vary depending on the agency and the unique scope of services the agency provides. Our Agency will prioritize PIPs as follows: Areas that affect patients first, High risk areas for opportunities and improvementOur agency will document: All QA projects undertaken, The reasons for conducting these projects, The measurable progress achieved on the projects." The QAPI program documentation was requested on February 9, 2026, at approximately 11:30 AM. The agency Administrator/Director of Nursing could not provide any documentation pertaining to the QAPI program. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that it did not conduct performance improvement projects (PIPs) as part of its QAPI program, and documentation of projects was not available at the time of survey. The agency has implemented a corrective action plan to ensure that PIPs are conducted, documented, and monitored for measurable outcomes.
The absence of documented PIPs placed patients at risk for missed opportunities to improve quality, safety, and outcomes. The agency performed conducted a retrospective review of all patient care records from the past 12 months. Any deficiencies will be corrected immediately through updated care plans, staff notifications, and physician coordination.


To ensure PIPs are conducted as required: the agency develop an annual schedule of at least three performance improvement projects. Each PIP will include a defined goal, baseline data, interventions, measurable outcomes, and a timeline for implementation. Staff will be trained on PIP methodology, data collection, and reporting requirements.

The agency will implement ongoing monitoring to ensure PIP effectiveness and sustainability.

Any PIP that does not achieve measurable outcomes will trigger immediate corrective interventions and process adjustments. Quarterly reports to the governing body will include PIP status, outcomes, and recommendations for further improvement.
Monitoring is ongoing and will continue indefinitely as part of the agency's QAPI program.


484.80(c)(5) ELEMENT
Documentation of competency evaluation

Name - Component - 00
The HHA must maintain documentation which demonstrates that the requirements of this standard have been met.

Observations: Based on a review of agency policies/procedures, review of personnel files (PF), and an interview with the Administrator/Nursing Director (PF#1), the agency failed to ensure documentation of competency evaluation for clinical staff for ten (10) of the ten (10) PFs requested. (PF#1-10) Findings include: A review of agency's policy conducted on February 17, 2026, at approximately 9am revealed the following: Agency policy titled "Competency Skills Testing: Clinical Staff" stated, "POLICY:It is the policy of Guaranteed Home Health Services, Inc. d/b/a Always A Step Beyond to provide skills competency evaluations at the time of hire and annually thereafter, and as needed based on performance, for clinical professional and paraprofessional staff to ensure the highest quality of consumer care.Skills competencies are performed on hire and at least annually..." A review of personnel files conducted on February 10, 2026, between approximately 10:30 am to 11:30 am, and again on February 17, 2026, at approximately 10am, revealed the following: PF#1 Date of hire (DOH) 6/20/25: Contained no documentation verifying skills competency evaluation on hire. (Administrator/Director of Nursing) PF#2 DOH 9/28/23: Contained no documentation verifying skills competency evaluation on hire. No documentation of skill competency evaluation for year 2024 and 2025. Licensed Practical Nurse providing services to CF#2. PF#3 DOH 11/24/25: Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#5 PF#4 DOH 8/25/25: Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#4 PF#5 DOH 8/23/25: Contained no documentation verifying skills competency evaluation on hire.) Home Health Aide providing services for CF#6 PF#6 DOH 7/8/25: Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#6 PF#7 DOH 1/15/25: Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#3 PF#8 No DOH documented. Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#1 PF#9 No DOH documented. Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#1 PF#10 No DOH documented. Contained no documentation verifying skills competency as the Alternate Administrator. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that it failed to maintain documentation of competency evaluations for clinical staff at the time of hire and annually thereafter, as required by agency policy and regulation. The agency has developed and implemented a corrective action plan to ensure staff competency is verified, documented, and monitored consistently.
The lack of documented competency evaluations placed patients at risk of receiving care from staff whose skills were not verified. The agency will conduct a retrospective competency assessment for all clinical staff currently employed and those who provided care in the past 12 months. This will ensure that staff providing care to patients have the necessary skills to safely provide services. The DON will immediately address any deficiencies in clinical knowledge or skills through targeted education, skills demonstration, or reassignment if necessary.

To ensure no patients are missed the agency will generate a list of all patients currently receiving services and those discharged within the last 12 months and cross-reference staff assigned to each patient with staff who lacked documented competency evaluations.

To prevent recurrence, all clinical staff will undergo competency evaluation at the time of hire, annually thereafter, and as needed based on performance. Staff will complete required skills review annually, including any changes in procedures, equipment use, or agency policy.
To ensure ongoing compliance: the DON will review competency documentation for all staff monthly and audit 10% of personnel files for verification of competency evaluations every quarter. Any gaps or deficiencies discovered during audits will trigger immediate corrective action, including additional training or reassignment. Monitoring and reporting will continue indefinitely to ensure competency compliance is sustained.



484.105(a) STANDARD
Governing body

Name - Component - 00
Standard: Governing body.
A governing body (or designated persons so functioning) must assume full legal authority and responsibility for the agency's overall management and operation, the provision of all home health services, fiscal operations, review of the agency's budget and its operational plans, and its quality assessment and performance improvement program.

Observations: Based on a review of agency policy and procedure, agency documentation, and interview with the Administrator/Director of Nursing (PF#1), it was determined the Governing body (GB) and the agency failed to follow its own policy and conduct a two (2) person governing body meeting and ensure documentation in regards to the reviewing and approval the the annual program evaluation and the agency policies for one (1) of one (1) GB reviewed. (GB#1) Findings include: Review of agency policy was conducted on February 11, 2026, at approximately 11:30 AM and revealed the following: Policy titled, "Governing Body" stated "Procedure: 1. General: a. MEMBERS of the GB: The GB will be no less than 2 individuals, at least 21 years of age. ...these rules be reviewed and approved annually as part of the Agency annual evaluation..." Policy titled, "Agency Evaluation Policy" stated, " 3. ANNUAL EVALUATION RESULTS PROCESSING a. Once the team has completed review of all the evaluation areas, the Annual Evaluation document will be completed, signed/dated &; presented to the Governing Body for review &; final approval." GB#1-Review of agency documentation on February 10, 2026, at approximately 11:25 AM revealed documentation of Governing Body meetings held on January 31, 2026. There was no documentation contained in this meeting minutes about annual budget or the review and approval of the annual program evaluation or agency policies. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that the governing body failed to conduct and document a meeting that reviewed and approved the annual program evaluation and agency policies in accordance with agency policy. Lack of proper governing body oversight may indirectly affect patient care, quality assurance, and operational decision-making. There will be an immediate review of the 2025 Annual Program Evaluation and all current agency policies by the Governing Body to ensure compliance.

All patients active during the period of missing governing body oversight will be reviewed to confirm that quality and safety indicators were monitored appropriately through other internal checks. Any patients whose care may have been impacted by policies not reviewed or approved will be identified, and corrective actions will be implemented, such as review of care plans, documentation, and compliance with established agency standards.

To prevent recurrence The agency will at least annually wit al least 2 members. Meeting minutes will documented as evidence. The agency created an Annual meeting Calendar and send to each governing body members.
Director of Nursing/Administrator will audit the Governing Body minutes annually to ensure compliance.




484.105(b)(1)(i) ELEMENT
Administrator appointed by governing body

Name - Component - 00
Standard: Administrator. The administrator must:
(i) Be appointed by and report to the governing body;

Observations: Based on a review of agency policy/procedure, personnel files (PF), agency documentation, and an interview with the Administrator/Director of Nursing (PF#1), it was revealed that the Governing body (GB) failed to appoint a qualified professional to act as the Agency Administrator in writing for one (1) of one (1) GB reviewed. (GB#1) . Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:15 PM and revealed the following: Agency policy titled "Administrator/Alternate Administrator stated, "POLICY:It is the policy of the Agency for the Governing Body to designate in writing, a qualified professional to act as the Agency Administrator and for the Governing Body/Administrator, to select a pre-designated Alternate Administrator to act in the absence of the Agency Administrator. Both will be available during all operating hours. Based on a review of agency policy/procedure, personnel files (PF), agency documentation, and an interview with the Administrator/Director of Nursing (PF#1), it was revealed that the Governing body (GB) failed to appoint a qualified professional to act as the Agency Administrator in writing for one (1) of one (1) GB reviewed. (GB#1) . Personnel review conducted on February 9, 2026, at approximately 11:50 am revealed the following: PF#1 Date of hire 6/20/2026: Did not contain a signed job description for the role of administrator. Contained no documentation of competency, skill assessments, or performance evaluation. On February 10, 2026, at approximately 2:30 PM, during an interview with the administrator, he reported not being familiar with Home Health surveys. He reported only knowing the survey process of nursing homes. When I asked him for the orders for the skilled case, he informed me the doctor's orders were in the patient's home. On February 9, 2026, at approximately 2:25pm, PF#1 reported that he had to go pick up a child in New Jersey where he lives. There was no other administrator available for oversight or in the event of an emergency. GB#1- Reviewed Governing body minutes conducted on February 9, 2026, at approximately 3 PM revealed, The Governing body minutes dated 1/31/2026, approved PF#1 as the administrator and the owner as the alternate. On February 10, 2026, surveyor requested the personnel files of the alternate and the previous administrator. The agency failed to provide termination date and personnel file for the previous administrator. The agency failed to provide the personnel file for the alternate administrator/owner, who resides in Boston. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that the Governing Body failed to appoint a qualified professional as Agency Administrator in writing and ensure documentation for the alternate administrator. Lack of a properly appointed administrator may indirectly affect patient care oversight, operational decision-making, and regulatory compliance. The Governing Body has formally appointed the current Administrator in writing, including a detailed job description, scope of authority, and responsibilities.

To prevent recurrence the Governing Body will appoint the Administrator and Alternate Administrator in writing annually or as changes occur. Job descriptions, competencies, and performance expectations will be documented in personnel files.
The Governing Body will conduct quarterly audits of personnel files to ensure: Written appointment of Administrator and Alternate Administrator exists, Job descriptions are current and signed, Competency assessments and performance evaluations are documented. Findings will be reported during QAPI meetings and any gaps will trigger immediate corrective action.




Initial Comments:Based on the findings of an unannounced onsite relicensure survey initiated February 9, 2026 through February 10, 2026 and completed February 27, 2026, Always A Step Beyond, was found to not be in compliance with the requirements of 28 PA Code, Part IV, Health Facilities, Subpart G. Chapter 601. 
Plan of Correction:




601.3 REQUIREMENT
COMPLIANCE W/ FED, ST, & LOCAL LAWS

Name - Component - 00
601.3 COMPLIANCE WITH FEDERAL,
STATE AND LOCAL LAWS.
The home health agency and its staff
are in compliance with all applicable
Federal, State and Local Laws and
regulations.

Observations: Based on review of agency policies/procedures, clinical records (CR) and "PA Code, Title 49, Chapter 21. State Board of Nursing, Subchapter A. Registered Nurses"; and based on an interview with the Administrator/Director of Nursing (PF#1), the agency failed to ensure that patient care orders and a plan of care were developed and implemented by a Registered Nurse and authorized by a physician prior to the delivery of services for six (6) of the six (6) CRs reviewed(CR#1-6) Findings include: Review of the agency policy conducted on February 13, 2026 at approximately 9am revealed the following: Agency policy titled "Records: Clinical" stated, "Procedure...8. Clinical Record Documentation...Entry Basics: All record entries into the clinical record by all disciplines, for care/services rendered, are written at the time the service is rendered, by the primary person providing the care/service and shall be incorporated into the patient's clinical record with 7 days of the delivery of service..." Review of the agency policy titled "Verbal Orders" on February 9, 2026 at approximately 9:30am revealed the following: "Procedure...The orders must be put into writing by personnel authorized to do so by applicable state laws and regulations as well as by agency internal policies. The orders must be signed and dated with the date of receipt by the nurse...responsible for furnishing or supervising the ordered services..." On February 13, 2026 at 9:25 AM, review of PA Code, Title 49, Chapter 21. State Board of Nursing, Subchapter A. Registered Nurses revealed the following: "21.11. General functions...(a) The registered nurse assesses human responses and plans, implements and evaluates nursing care for individuals or families for whom the nurse is responsible. In carrying out this responsibility, the nurse performs all of the following functions: (1) Collects complete and ongoing data to determine nursing care needs. (2) Analyzes the health status of the individuals and families and compares the data with the norm when possible in determining nursing care needs. (3) Identifies goals and plans for nursing care... 21.18. Standards of nursing conduct. (a) A registered nurse shall: (5) Document and maintain accurate records..." A review of Clinical records (CR) conducted on February 9, 2026 at approximately 11:00 A.M to 1:00 PM, and again on February 10, 2026, at approximately 1PM which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a "Home Health Certification and Plan of Care (POC)." File contained no documentation of any physician orders enabling agency to conduct services.The Calendar revealed HHA visits Monday - Friday from 7 am -4 pm, then 8:30 pm -4:30 am. Saturday and Sunday 7 am -2 pm, then 8:30 pm-4:30 am. No documentation of any Registered Nurses (RN) notes. CR#2 SOC 6/29/2023: Contained no documentation of a "Home Health Certification and Plan of Care." File contained no documentation of any physician orders enabling agency to conduct services.A document titled "Client Profile" revealed a SOC of 6/29/2023, admission diagnosis Cerebral Palsy, unspecified, primary diagnosis oth generalized epilepsy, not intractable, w stat epi, secondary diagnosis cortical blindness, right side of brain. The Calendar revealed LPN visits started on June 30, 2023. From September 5, 2025 to February 7, 2026, 1-5 times a week from 8pm to 7am. No documentation of any RN notes. CR#3 SOC 1/27/2026: Contained no documentation of a "Home Health Certification and Plan of Care" File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 1/20/2026, admission diagnosis Down syndrome, unspecified. The Calendar revealed HHA visit started on 2/3/26, from 9am to 12pm. No documentation of any RN notes. CR#4 SOC 2/4/2026: Contained no documentation of a "Home Health Certification and Plan of Care" File contained no documentation of any physician orders enabling agency to conduct services. No documentation of any RN notes.A document titled "Client Profile" revealed a SOC of 1/26/2026, admission diagnosis Unspecified convulsions, secondary diagnosis Epileptic spasms, intractable, with status epilepticus. The Calendar revealed HHA visit started on 2/8/26 from 12pm-8pm, Monday to Friday from 3pm-11pm, and Sunday from 12pm to 8pm. No documentation of any RN notes. CR#5 SOC 11/24/2025: Contained no documentation of a "Home Health Certification and Plan of Care." File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 11/24/2025, admission diagnosis Congenital hypotonia, primary diagnosis, Congenital hypotonia, secondary diagnosis Congenital hypotonia, and services required Home Health Aide. The Calendar revealed HHA visit started on November 25, 2025. Monday to Sunday from 2pm to 10pm, then 10:00 pm to 6am. No documentation of any RN notes. CR#6 SOC 4/23/2025: Contained no documentation of a "Home Health Certification and Plan of Care." File contained no documentation of any physician orders enabling agency to conduct services.A document titled "Client Profile" revealed a SOC of 4/23/2025, admission diagnosis Autistic disorder, Primary diagnosis Autistic disorder, secondary diagnosis Mixed receptive-expressive language disorder, and services required Home Health Aide. The Calendar revealed HHA visit started on 8/1/2025 from 9:30 am-3:30 pm. Visits times documented as follows: Monday, Tuesday Saturday and Sunday from 9:30 AM to 3:30 PM, Wednesday, Thursday and Friday 9:30 am to 3:30 pm and 5:30 pm to 9:30 pm. No documentation of any RN notes. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the finding that patient care orders and plans of care were not consistently developed and implemented by a Registered Nurse and authorized by a physician prior to the delivery of services. The agency has taken immediate and long-term corrective actions to ensure full compliance with Federal, State, and Local laws. All six (6) patients identified in the review had their records audited by the agency's Administrator and Director of Nursing. Physician Orders and Plans of Care: Missing physician orders and Home Health Certification/Plan of Care (POC) were obtained, documented, and incorporated into each patient's record. RN evaluations were conducted for all affected patients to ensure accurate assessment, implementation, and documentation of nursing care. Clinical staff involved in the care of these patients were retrained on policy requirements for obtaining physician orders and RN-authored POCs before service delivery.

The DON conducted an audit of all active patients to compliance with the requirements.
To prevent recurrence all new admissions now require RN verification of Signed physician orders and that services cannot begin without verification by the Administrator or RN. All clinical staff received retraining on compliance per the agency policy and regulations.

The administrator or the DON will conduct a Weekly Audit of New Admissions. The Administrator or Director of Nursing will review all new admissions for proper RN-authorization POC and physician orders. Any deficiencies will be corrected within 24 hours. A monthly Compliance Report will be presented at monthly QAPI meetings and reviewed by the Governing Body. Findings from audits and compliance reports will inform performance improvement projects to prevent recurrence.



601.21(c) REQUIREMENT
GOVERNING BODY

Name - Component - 00
601.21(c) Governing Body. A governing
body (or designated persons so
functioning) assumes full legal
authority and responsibility for the
operation of the agency. The
governing body appoints: (i) a
qualified administrator, (ii) arranges
for professional service, (iii) adopts
and periodically reviews written
bylaws or an acceptable equivalent,
and (iv) oversees the management and
fiscal affairs of the agency. The
name and address of each officer,
director, and owner are disclosed to
the State agency with changes reported
promptly.



Observations: Based on a review of agency documentation, policy and procedure and interview with the Director of Nursing/Administrator and staff, it was revealed the agency failed to follow its own policy and conduct a two (2) person governing body meeting. The agency failed to ensure documentation in regards to the reviewing and approval the following: the annual program evaluation and the agency policies. Findings include: Review of agency policy was conducted on February 11, 2026 at approximately 11:30 AM and revealed the following: Policy titled, "Governing Body" stated "Procedure: 1. General: a. MEMBERS of the GB: The GB will be no less than 2 individuals, at least 21 years of age. ...these rules be reviewed and approved annually as part of the Agency annual evaluation..." Policy titled, "Agency Evaluation Policy" stated, " 3. ANNUAL EVALUATION RESULTS PROCESSING a. Once the team has completed review of all the evaluation areas, the Annual Evaluation document will be completed, signed/dated &; presented to the Governing Body for review &; final approval." Review of agency documentation on February 10, 2026, at approximately 11:25 AM revealed documentation of Governing Body meetings held on January 31, 2026. There was no documentation contained in this meeting minutes regarding the annual budget or the review and approval of the annual program evaluation or agency policies. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that the Governing Body did not conduct and document a two-person meeting that included review and approval of the annual program evaluation, budget, and agency policies as required by regulation and agency policy. Corrective actions have been implemented to ensure the Governing Body fully assumes legal authority and responsibility for the operation of the agency and maintains proper documentation of its activities. The Governing Body conducted an immediate formal meeting with two members present to review: The annual program evaluation, the agency's written policies and procedures, the agency's operational and fiscal status.

Meeting minutes were completed, signed, and maintained in the agency records. Any policy changes affecting clinical operations were communicated to staff and implemented immediately to ensure safe and compliant patient care.
To prevent recurrence the Governing Body will meet at least annually, with no fewer than two members present. A standing agenda template has been developed to ensure required topics are addressed at each meeting. All meeting documentation will be maintained in the Governing Body binder for survey readiness.
Governing Body members received education regarding their regulatory responsibilities under Pennsylvania home health regulations and agency bylaws.
To ensure sustained compliance the Administrator will maintain a Governing Body Compliance Calendar that tracks: Quarterly meeting dates, annual policy review deadlines, Annual program evaluation approval dates. During quarterly QAPI meetings, the agency will verify that Governing Body meetings occurred as scheduled
The Governing Body will review compliance with its own bylaws annually as part of the agency's performance improvement activities.



601.21(f) REQUIREMENT
PERSONNEL POLICIES

Name - Component - 00
601.21(f) Personnel Policies.
Personnel practices and patient care
are supported by appropriate, written
personnel policies. Personnel records
include qualifications, licensure,
performance evaluations, health
examinations, documentation of
orientation provided, and job
descriptions, and are kept current.

Observations: Based on a review of agency policies/procedures, personnel files (PF), clinical records (CR), and an interview with the Administrator/Director of Nursing (PF file #1), the agency did not follow its policies for CPR (cardiopulmonary resuscitation) certification in seven (7) of the ten (10) clinical staff PF's (PF#2-6, and PF#8-9) and TB testing of employees for six (6) of the ten (10) PF's (PF# 3,6,7,8,9,10); did not provide documentation of credentials on hire for five (5) of the ten (10) PF's (PF#5,7,8,9,and 10); did not provide job descriptions for seven (7) of the ten (10) PF's (PF #1, 3, 6,7,8,9,10); did not have criminal background checks for ten of the ten PFs. (PF1-10) Findings include: Review of the agency policy titled "Employee Qualifications/Standards" February 27, 2026, at approximately 9am revealed the following: "Procedure...Clinical personnel maintain current licensure and certifications...Qualifications: 1. ADMINISTRATOR/ALTERNATE ADMINISTRATORexperience in health services administration, with at least one (1) year of supervisory or administrative experience in home health care in a related health care programCLINICAL MANAGER 12. Home Health Aide (HHA)have successfully completed an Aide training program of no less than 75 hours which meets state and federal standards and have a certificate of completion. Will have successfully completed competency testing." Review of the agency policy conducted on February 27, 2026, at approximately 9:30 am revealed the following: Agency Policy titled "Hiring and Personnel files" stated, MAINTAINING PERSONAL FILES: Designated agency staff will maintain accurate, complete &; current individual personnel files for all agency staff, direct hire &; contracted, at our office locationPRE-HIRE All applicants require: A completed application, including employment history, identifying info (name, address, etc Resume (as applies) 2 Verifiable written or verbal positive references from a former employer or other person not related to the Applicant OIG Fraud Exclusions List Check (LEIE) (on-hire &; annually) Criminal Background Check...ON-HIRE employee will need: Verification of HHA training contentCopy of current CPR cardOrientation Instruction pageAgency hiring staff will verify that licenses/certifications are current &; unencumbered on hire &; renewal, for any staff position that is required to be licensed/certified (ie., RN, LPN, Therapists, Aides)TB testing: on hire &; annuallyTB QuestionnairesOrientation is required for all new hires and will incorporate a skills competence checklist for direct care workersof the agency policy conducted on February 27, 2026, at approximately 9:35 am revealed the following: Agency Policy titled "Job descriptions" stated, PROCEDURE:1. Job Description includes: a. Job summary describing the key tasks and responsibilities. b. Organizational relationships defining the reporting structure in the organization. c. Qualifications for administrative and management position which are clearly defined and are consistent with the scope of responsibility and the complexity of the organization, as well as qualification for paraprofessional employeesJob Descriptions are: Distributed during the orientation process. Reviewed with each new hire to assure an understanding of the expected tasks and accountability of the roleof the agency policy conducted on February 27, 2026, at approximately 9:40 am revealed the following: Agency Policy titled "Criminal background policy" stated, "POLICY: the vulnerable populations of elders and children by adhering to the requirement of performing criminal background checks and all other state and federal mandated checks prior to hire for all employeesAll owners and all employees of the Agency are required to have current criminal history checksindividual shall obtain a Federal criminal history check and a letter of determination from the PA Department of Aging based on the Federal criminal history check... Serving persons under 18: If our agency services persons under the age of 18 years, all staff will have a ChildLine clearance and acquire the following three (3) certification: Report of criminal history from the Pennsylvania State Police Fingerprint based federal criminal history..." A Personnel file review was conducted on February 9, 2026, at approximately 12pm, on February 10, 2026, between approximately 10:30 am and 11:45 am, then again on February 27 at approximately 8:30 am, revealed the following: PF#1 Date of hire (DOH) 6/20/25: Did not contain documentation of the following: A job description for Administrator, a Childline clearance, a federal background criminal history with a letter from the department of aging, a completed TB risk and symptom questionnaire. PF#2 DOH 9/28/23: Did not contain documentation of the following: A federal criminal background check with a letter from the department of aging, a current CPR certification, TB annual questionnaires. PF#3 DOH 11/24/25: Did not contain documentation of the following: A job description for Home Health Aide (HHA), a Pennsylvania State Police (PATCH) background check, A Federal criminal background check with a letter from the department of aging, a current CPR certification, Orientation verification, TB test or TB risk and symptom screening questionnaires. PF#4 DOH 8/25/25: Did not contain documentation of the following: A federal criminal background check with a letter from the department of aging, a Childline clearance, a current CPR certification, Orientation verification, TB risk and symptom screening questionnaires. PF#5 DOH 8/23/25: Did not contain documentation of the following: A federal criminal background check with a letter from the department of aging, a current CPR certification, HHA certification, Orientation verification, TB test and TB risk and symptom screening questionnaires upon hire. PF#6 DOH 7/8/25: Did not contain documentation of the following: A Job description for HHA, a federal criminal background check with a letter from the department of aging, a Childline clearance, a current CPR certification, Orientation verification, TB test upon hire. PF#7 DOH 1/15/25: Did not contain documentation of the following: A Job description for HHA, a federal criminal background check with a letter from the department of aging, HHA certification, Orientation verification, TB test upon hire. PF#8, PF#9 two (2) HHA files servicing CR#1 were not provided as requested. PF#10- Alternate administrator- were not provided as requested. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that personnel files were incomplete and did not contain required documentation including CPR certification, TB screening, job descriptions, background checks, credentials, and orientation records. The agency has implemented immediate and systemic corrective actions to ensure all personnel records are complete, current, and maintained in accordance with Federal and Pennsylvania regulations.
The agency conducted an immediate review of all active clinical staff files. Staff who were missing required documentation were: removed from direct patient care duties until required clearances, certifications, and health screenings were completed. staff were required to provide current CPR certification, TB screening, and proof of credentials prior to returning to patient assignments. Criminal background checks, ChildLine clearances, and federal fingerprinting were obtained for all staff who did not have these documents on file. Updated job descriptions were issued, reviewed with staff, and signed.

To prevent recurrence the agency has implemented : A standardized Personnel File Audit Checklist was developed to ensure all required documents are present before hire and maintained annually. Pre-Hire Clearance Requirement that Staff cannot begin employment or provide patient care until all required background checks, credentials, and health screenings are verified and documented. The agency created a tracking log to monitor expiration dates of CPR and licenses, annual TB screening due dates and performance evaluation schedules
Administrative staff responsible for hiring and file maintenance were re-educated.
To ensure sustained compliance: The Administrator will conduct monthly audits of 100% of personnel files for three months, then quarterly thereafter. Findings will be reported to the Governing Body and included in the QAPI program as a monitored compliance indicator. Any missing documentation identified during audits will be corrected immediately, and staff will be removed from patient care if required credentials lapse.




601.21(h) REQUIREMENT
COORDINATION OF PATIENT SERVICES

Name - Component - 00
601.21(h) Coordination of Patient
Services. All personnel providing
services maintain liason to assure
that their efforts effectively
complement one another and support the
objectives outlined in the plan of
treatment. (i) The clinical record
or minutes of case conferences
establish that effective interchange,
reporting, and coordinated patient
evaluation does occur. (ii) A
written summary report for each
patient is sent to the attending
physician at least every 60 days.

Observations: Based on a review of agency policy, clinical records (CR), and interview with the Administrator/Director of Nursing (PF#1), it was determined that the agency failed to follow agency policy and send the required 60 day summary to the patient's physician for ... A review of the agency's policy and procedure conducted on February 13, 2026 at approximately 9am, revealed the following: Agency policy titled, "Coordination Of Care/Patient Education" states, "POLICY: Coordination of care will occur for each of the Agency's Patients. Our Agency's management/supervisory staff shall assume responsibility for coordination of care across the service disciplines for each Patient with all physicians providing orders to the Agency for a patient POC." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral. There was also no documentation of a new care plan developed every 55-60 days. CR#2 SOC 6/29/2023: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral. There was also no documentation of a new care plan developed every 55-60 days. CR#3 SOC 1/20/2026: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments ,any safety measures to protect against injury, instructions for timely discharge or referral. CR#4 SOC 2/4/2026: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral. CR#5 SOC 11/24/2025: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments ,any safety measures to protect against injury, instructions for timely discharge or referral. There was also no documentation of a new care plan developed every 55-60 days. CR#6 4/23/2025: No documentation of a plan of treatment/physician orders developed in consultation with the agency staff covering all pertinent diagnoses, including: mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments ,any safety measures to protect against injury, instructions for timely discharge or referral. There was also no documentation of a new care plan developed every 55-60 days. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that treatment plans were not developed, updated, or communicated to the attending physician every 60 days as required. The agency also failed to maintain documentation of interdisciplinary coordination and case conference communication. Immediate corrective actions and system-wide changes have been implemented to ensure coordinated patient care and physician communication in accordance with state regulations.
All patients identified in the survey findings were reviewed immediately. The Director of Nursing contacted each patient's attending physician to: Obtain or update physician orders, establish or revise a comprehensive plan of treatment addressing diagnoses, services, visit frequency, medications, safety measures, and discharge planning. A written 60-day summary report was completed and transmitted to each patient's physician. Clinical records were updated to include: Signed plans of treatment, Interdisciplinary communication notes, Documentation of physician correspondence.

The agency conducted a 100% audit of all active and recently discharged patient clinical records for compliance. Any additional patients identified without current physician orders or care plan updates had an immediate care plan development or revision and Physician notification and documentation added to the clinical record.
The agency implemented a 60-Day Recertification and Summary Tracking Log to monitor plan of treatment due dates, 60-day summary report deadlines and Physician signature status.
All clinical and administrative staff received training on requirements
To ensure ongoing compliance The Director of Nursing will perform monthly audits of 100% of active patient records for three months, followed by quarterly audits thereafter. Results will be reviewed during Quality Assurance and Performance Improvement (QAPI) meetings and reported to the Governing Body. Any missed deadlines or documentation gaps identified during monitoring will result in immediate corrective action and staff re-education.





601.22(d) REQUIREMENT
CLINICAL RECORD REVIEW

Name - Component - 00
601.22(d) Clinical Record Review. At
least quarterly, appropriate health
professionals, representing at least
the scope of the program, review a
sample of both active and closed
clinical records to assure that
established policies are followed in
providing services (direct as well as
services under arrangement). There is
a continuing review of clinical
records for each 60-day period that a
patient receives home health services
to determine adequacy of the plan of
treatment and appropriateness of
continuation of care.

Observations: Based on review of agency policy and procedures, review of agency documents, and an interview with Administrator/Director of Nursing (PF#1), the agency failed follow its own policy to perform periodic clinical record review (CRR) for one of the one clinical review reviewed. (CRR#1) Findings include: Agency policy review conducted on February 17, 2026, at 10am revealed the following: Agency policy titled "Care/Services Routinely Assessed/CRR" states, "POLICY: The adequacy, appropriateness, effectiveness and outcomes of care/services provided to Agency patients are assessed ongoing through clinical record reviews. PROCEDURE: Care and services provided to our patients are routinely assessed relative to adequacy, appropriateness, effectiveness and outcomes primarily through the Clinical Record Review process through oversight of the QA Clinical Outcome Committee. Clinical Outcome Committee Responsibilities:1. Clinical Record Review (CRR)- quarterly through the QA Clinical Outcomes Committee. Reviews are based on specific criteria and include, but are not limited to: Services rendered, Following established agency policies POC Need for continued services Reviews are documented on the Agency Record Review Form." A review of agency documents conducted of February 10, 2026, at approximately 2:15 pm, revealed the following: CRR#1- Contained a document titled "Clinical Record Review Meeting Minutes" dated 3/28/2026. It did not specifically document the following: Services rendered,Following established agency policies, Plan of Care (POC), and the need for continued services. There was also no documentation provided on an agency review form for individual patients that were reviewed. No other documentation on clinical reviews was provided. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that it did not conduct and document quarterly clinical record reviews in accordance with its own policy. Documentation did not include required elements such as services rendered, adherence to agency policies, adequacy of the plan of care, and need for continued services. Corrective actions have been implemented to ensure clinical record reviews are completed quarterly, properly documented, and used to evaluate the effectiveness and appropriateness of patient care.
The Director of Nursing conducted an immediate retrospective review of all active patient clinical records to evaluate compliance with the requirements. Any discrepancies identified during the review were corrected. To prevent recurrence the Quality Assurance Clinical Outcomes Committee has been formally re-established and scheduled to meet quarterly with participation from appropriate health professionals representing the scope of services provided by the agency. The agency developed and implemented a Clinical Record Review Form that includes required elements. The Administrator and clinical staff received re-education on requirements.

To ensure ongoing compliance the Administrator will maintain a Quality Assurance calendar identifying due dates for quarterly clinical record reviews. Meeting minutes and completed Clinical Record Review Forms will be maintained and reviewed during Governing Body and QAPI meetings. The Director of Nursing will verify completion of each quarterly review and ensure corrective actions identified during reviews are implemented and tracked to completion. Compliance with quarterly clinical record review requirements will be reported as a standing agenda item during QAPI meetings.



601.31(b) REQUIREMENT
PLAN OF TREATMENT

Name - Component - 00
601.31(b) Plan of Treatment. The
plan of treatment developed in
consultation with the agency staff
covers all pertinent diagnoses,
including:
(i) mental status,
(ii) types of services and equipment
required,
(iii) frequency of visits,
(iv) prognosis,
(v) rehabilitation potential,
(vi) functional limitations,
(vii) activities permitted,
(viii) nutritional requirements,
(ix) medications and treatments,
(x) any safety measures to protect
against injury,
(xi) instructions for timely
discharge or referral, and
(xii) any other appropriate items.
(Examples: Laboratory procedures and
any contra-indications or
precautions to be observed).

If a physician refers a patient under
a plan of treatment which cannot be
completed until after an evaluation
visit, the physician is consulted to
approve additions or modifications to
the original plan.

Orders for therapy services include
the specific procedures and modalities
to be used and the amount, frequency,
and duration.
The therapist and other agency
personnel participate in developing
the plan of treatment.

Observations: Based upon clinical record review, agency policy review, and an interview with the Director of Nursing/Administrator and staff, it was determined the agency failed to ensure a Home Health Certification and Plan of Care/Treatment was created for six (6) out of six (6) clinical record reviewed (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 11:30 AM and revealed the following: Agency policy titled "Plan of Care (POC)" stated, " Policy: Each patient will receive home health services that are written in an individual plan of care that identifies patient-specific measurable outcomes and goals, which is established, periodically reviewed and signed by a physician...2. POC development: The POC is: b. Developed within 5 days of the SOC/ROC or Follow UP Assessment...g. Must be signed by the attending...p Administrator/Clinical Manager or Nursing Supervisor shall review the plan of care for completeness prior to it being submitted to MD for signature...r. A copy of the POC shall be maintained in the patient's clinical record...3. POC UPDATES/REVISIONS: A revised POC must reflect current information from the patients updated comprehensive assessment...a. The POC is updated/revised: i. At least every 60 days beginning with the SOC date. ii. Upon initial assessment and development of the 485. iii. As new orders are received. vi. At Follow Up Recertification periods...b. Update process: At time of recertification, a written summary of the patient's status and the services being provided, is submitted with the POC for physician review... 4. POC INCLUDES All pertinent diagnosisb. Patients mental, Psychosocial, and cognitive status c. Types of services, supplies, and equipment needs. d. Frequency &; duration of visits of be made e. Prognosis, f. Rehab Potential g. Functional Limitations h. Activities permitted i. Nutritional requirements j. All medications and treatments k. Safety measures to protect against injury..." A review of Clinical records (CR) conducted on February 9, 2026 at approximately 11:00 A.M to 1:00 PM, and again on February 10, 2026, at approximately 1PM which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items.File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 12/7/2023, admission diagnosis Autistic disorder, primary diagnosis Autistic disorder, secondary diagnosis pervasive developmental disorder unspecified. The Calendar revealed HHA visits Monday - Friday from 7 am -4 pm, then 8:30 pm -4:30 am. Saturday and Sunday 7 am -2 pm, then 8:30 pm-4:30 am. CR#2 SOC 6/29/2023: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 6/29/2023, admission diagnosis Cerebral Palsy, unspecified, primary diagnosis oth generalized epilepsy, not intractable, w stat epi, secondary diagnosis cortical blindness, right side of brain. The Calendar revealed LPN visits started on June 30, 2023. From September 5, 2025 to February 7, 2026, 1-5 times a week from 8pm to 7am. CR#3 SOC 1/27/2026: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 1/20/2026, admission diagnosis Down syndrome, unspecified. The Calendar revealed HHA visit started on 2/3/26, from 9am to 12pm. CR#4 SOC 2/4/2026: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 1/26/2026, admission diagnosis Unspecified convulsions, secondary diagnosis Epileptic spasms, intractable, with status epilepticus. The Calendar revealed HHA visit started on 2/8/26 from 12pm-8pm, Monday to Friday from 3pm-11pm, and Sunday from 12pm to 8pm. CR#5 SOC 11/24/2025: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 11/24/2025, admission diagnosis Congenital hypotonia, primary diagnosis, Congenital hypotonia, secondary diagnosis Congenital hypotonia, and services required Home Health Aide. The Calendar revealed HHA visit started on November 25, 2025. Monday to Sunday from 2pm to 10pm, then 10:00 pm to 6am. CR#6 SOC 4/23/2025: Contained no documentation of a "Home Health Certification and Plan of Care" and therefore did not contain the following: a. All pertinent diagnosis, b. Patients mental, Psychosocial, and cognitive status, c. Types of services, supplies, and equipment needs, d. Frequency &; duration of visits of be made, e. Prognosis, f. Rehab Potential, g. Functional Limitations, h. Activities permitted, i. Nutritional requirements, j. All medications and treatments, k. Safety measures to protect against injury, and other appropriate items. File contained no documentation of any physician orders enabling agency to conduct services. A document titled "Client Profile" revealed a SOC of 4/23/2025, admission diagnosis Autistic disorder, Primary diagnosis Autistic disorder, secondary diagnosis Mixed receptive-expressive language disorder, and services required Home Health Aide. The Calendar revealed HHA visit started on 8/1/2025 from 9:30 am-3:30 pm. Visits times documented as follows: Monday, Tuesday Saturday and Sunday from 9:30 AM to 3:30 PM, Wednesday, Thursday and Friday 9:30 am to 3:30 pm and 5:30 pm to 9:30 pm. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that a Home Health Certification and Plan of Care was not created or maintained for six (6) of six (6) clinical records reviewed. The agency also acknowledges that services were initiated without documented physician orders and without a comprehensive plan of treatment containing required clinical elements. Immediate corrective action and systemic changes have been implemented to ensure all patients receive services only under a physician-approved plan of treatment that meets regulatory requirements.

All patients identified in the survey findings were reviewed immediately. Services were reviewed to ensure they were medically necessary and consistent with physician orders. Where needed, services were suspended until appropriate orders were received.

To ensure no other patients were receiving services without a compliant plan of treatment the agency conducted a 100% audit of all active and recently discharged patient clinical records to verify.
To prevent recurrence the agency implemented a plan of care checklist to ensure all required regulatory elements are included and cannot be finalized unless all fields are completed. A tracking log was implemented to ensure plan of care are in compliance with the requirements.
The Administrator/Clinical Manager must review each plan of care for completeness prior to submission to the physician and again upon return for signature. All administrative and clinical staff received training on regulatory requirements for plans of treatment.
To ensure continued compliance The Director of Nursing will conduct weekly audits of all new admissions for three months to verify that plans of care are created within required timeframes and signed by physicians. Thereafter, audits will be conducted monthly and reported to the Quality Assurance and Performance Improvement (QAPI) program and Governing Body. Any identified deficiencies will be corrected immediately, and staff will receive re-education as necessary.



601.31(d) REQUIREMENT
CONFORMANCE WITH PHYSICIAN'S ORDERS

Name - Component - 00
601.31(d) Conformance With
Physician's Orders. All prescription
and nonprescription (over-the-counter)
drugs, devices, medications and
treatments, shall be administered by
agency staff in accordance with the
written orders of the physician.
Prescription drugs and devices shall
be prescribed by a licensed physician.
Only licensed pharmacists shall
dispense drugs and devices. Licensed
physicians may dispense drugs and
devices to the patients who are in
their care. The licensed nurse or
other individual, who is authorized by
appropriate statutes and the State
Boards in the Bureau of Professional
and Occupational Affairs, shall
immediately record and sign oral
orders and within 7 days obtain the
physician's counter-signature. Agency
staff shall check all medicines a
patient may be taking to identify
possible ineffective drug therapy or
adverse reactions, significant side
effects, drug allergies, and
contraindicated medication, and shall
promptly report any problems to the
physician.

Observations: Based upon agency policy review, clinical record (CR) review, and an interview with the Administrator/Director of Nursing (PF#1), it was determined the agency failed to obtain a physician order for services, and treatments and/or medications for six (6) of the six (6) CRs reviewed. (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 2:00 PM and revealed the following: Agency policy titled " Physician Services" stated, "POLICY: Drugs, services and treatments are administered by Agency staff only as ordered by a physicianreview of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026 at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no evidence of any physician orders. CR#2 SOC 6/29/2023: Contained no evidence of any physician orders. CR#3 SOC 1/20/2026: Contained no evidence of any physician orders. CR#4 SOC 2/4/2026: Contained no evidence of any physician orders. CR#5 SOC 11/24/2025: Contained no evidence of any physician orders. CR#6 SOC 4/23/2025: Contained no evidence of any physician orders. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that services, treatments, and medications were provided without documented physician orders for six (6) of six (6) clinical records reviewed. The agency recognizes that this practice is not in compliance with state regulations or agency policy and has implemented immediate corrective actions and systemic safeguards to ensure all services are provided only under physician authorization.

All patients identified in the survey findings were reviewed immediately to ensure continuity of care and medical oversight. Any discrepancies between current care and physician direction were clarified with the physician and corrected immediately.
To ensure no other patients were receiving services without physician authorization the agency conducted a 100% audit of all active and recently discharged patient clinical records. Any patient record found lacking physician orders had orders obtained immediately and documented in the clinical record.
To prevent recurrence the agency has implemented, a Physician Order Tracking Log.
The Administrator/Director of Nursing must review each new admission file within 48 hours to verify that physician orders are present and complete. All clinical and administrative staff received training on requirements.

To ensure ongoing compliance The Director of Nursing will conduct weekly audits of all new admissions for three months to confirm that services are not initiated without physician authorization.

Thereafter, audits will be conducted monthly and incorporated into the agency's Quality Assurance and Performance Improvement (QAPI) program. Any deficiencies identified during monitoring will be corrected immediately and addressed through staff counseling and re-education.



601.32(a) REQUIREMENT
SUPERVISION

Name - Component - 00
601.32(a) Supervision. The home
health agency provides skilled nursing
service by or under the supervision of
a registered nurse and in accordance
with the plan of treatment.

Observations: Based on a review of agency policies/procedures, review of personnel files (PF), review of clinical records, and an interview with the Administrator/Nursing Director (PF#1), the Administrator/Director of Nursing failed to ensure that supervisions were performed for six (6) of the six (6) clinical PF(PF#2,3,5,6,8,9) that's providing services to four (4) of the six(6) CRs reviewed (CR#1,2, 5, 6) Findings include: A review of agency's policy conducted on February 17, 2026 at approximately 9:20 am revealed the following: Agency policy titled "Supervision :Clinical Staff" stated, "POLICY: Adequate, regular and timely supervisions of our Agency para professional staff, LPN, and therapy assistants shall occur. PROCEDURE...2. LPN staff shall be supervised: At least every consumer every 30 days by a RN...ii. NON-SKILLED CASES: Aide staff providing care for a patient not receiving skilled services, shall be supervised by an on-site visit: At least once every 60 days by a RN. The staff member will be present during the visit. A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:30 AM to 1:00 PM, on February 10, 2026, at approximately 1PM and on February 11, 2026, at approximately 12 PM, which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: A document titled "Client Profile" revealed a SOC of 12/7/2023, admission diagnosis Autistic disorder, primary diagnosis Autistic disorder, secondary diagnosis pervasive developmental disorder unspecified. The Calendar revealed HHA visits Monday - Friday from 7 am -4 pm, then 8:30 pm -4:30 am. Saturday and Sunday 7 am -2 pm, then 8:30 pm-4:30 am. Contained no evidence of a HHA supervisions performed by a Registered Nurse. CR#2 SOC 6/29/2023: A document titled "Client Profile" revealed a SOC of 6/29/2023, admission diagnosis Cerebral Palsy, unspecified, primary diagnosis oth generalized epilepsy, not intractable, w stat epi, secondary diagnosis cortical blindness, right side of brain, and services required Skilled Nurse. The Calendar revealed LPN visits 1-5 times a week from September 5, 2025, to February 7, 2026. Nurses note dated 1/10/2026, the LPN documented administering "all medication, feedings, and fluids " via G-tube. LPN documented on 1/11/26 "formula Compleat Pediatric @55ml/hr for a total volume of 450ml." LPN note dated 1/18/26, the LPN documented, "All medications, feedings, and fluids administered as ordered, well tolerated." Nurses note dated 1/24/2026, the LPN documented "saline drops administered to nostrils, rub chest ointment applied to the patient's chest per Dad request." Contained no evidence of any LPN supervisions by a Registered Nurse. CR#5 SOC 11/24/2025: A document titled "Client Profile" revealed a SOC of 11/24/2025, admission diagnosis Congenital hypotonia, primary diagnosis, Congenital hypotonia, secondary diagnosis Congenital hypotonia, and services required Home Health Aide. The Calendar revealed HHA visit started on 11/25/2025 from 2pm to 10pm, then 10om to 6am. Contained no evidence of a HHA any HHA supervisions performed by a Registered Nurse. CR#6 SOC 4/23/2025: A document titled "Client Profile" revealed, SOC of 4/23/2025, admission diagnosis Autistic disorder, Primary diagnosis Autistic disorder, secondary diagnosis Mixed receptive-expressive language disorder, and services required Home Health Aide. The Calendar revealed HHA visit started on 8/1/2025 from 9:30 am-3:30 pm. Visits times documented as follows: Monday, Tuesday Saturday and Sunday from 9:30 AM to 3:30 PM, Wednesday, Thursday and Friday 9:30 am to 3:30 pm and 5:30 pm to 9:30 pm. Contained no evidence of HHA supervisions performed by a Registered Nurse. A review of personnel files conducted on February 10, 2026, between approximately 10:30 am to 11:30 am, and again on February 17, 2026, at approximately 10am, revealed the following: PF#2 DOH 9/28/23: Contained no documentation verifying skills competency evaluations. Licensed Practical Nurse providing services to CF#2. PF#3 DOH 11/24/25: Contained no documentation verifying skills competency evaluations. Home Health Aide providing services for CF#5 PF#5 DOH 8/23/25: Contained no documentation verifying skills competency evaluations. Home Health Aide providing services for CF#6 PF#6 DOH 7/8/25: Contained no documentation verifying skills competency evaluations. Home Health Aide providing services for CF#6 PF#8 No DOH documented. Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#1 PF#9 No DOH documented. Contained no documentation verifying skills competency evaluation on hire. Home Health Aide providing services for CF#1 An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that required Registered Nurse (RN) supervision of Licensed Practical Nurses (LPNs) and Home Health Aides (HHAs) was not performed or documented in accordance with agency policy and state regulations. Additionally, personnel files did not contain competency evaluations for multiple clinical staff. Corrective actions have been implemented to ensure all paraprofessional and licensed staff are appropriately supervised and competency-validated.
All patients identified in the survey findings were reviewed immediately to ensure safe and appropriate care. The Director of Nursing conducted immediate supervisory visits for all active patients receiving services from HHAs and LPNs. Any necessary corrections to care delivery were implemented and documented in the clinical record.

To ensure no other patients were affected by lack of supervision the agency conducted a 100% review of all active patient assignments to identify any non-compliance. Any cases found with deficiency RN supervisory visits were scheduled and completed for any patient lacking required oversight.
The agency implemented a Supervision Tracking Log, a Competency Evaluation checklist
To ensure sustained compliance the Director of Nursing will conduct monthly audits of all active cases for three months to ensure compliance with the requirements. Thereafter, supervision compliance will be reviewed quarterly through the agency's Quality Assurance and Performance Improvement (QAPI) program.



601.36 REQUIREMENT
CLINICAL RECORDS

Name - Component - 00
601.36 IX. CLINICAL RECORDS.


Observations: Based on a review of agency policy/procedures, clinical record (CR) review, and an interview with the Administrator/Director of Nursing (PF#1), the agency failed to ensure that complete clinical records were maintained for patients receiving services for six (6) of the six (6) CR reviewed. (CR1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 11:30 AM and revealed the following: Agency policy titled "Plan of Care (POC)" stated, " Policy: Each patient will receive home health services that are written in an individual plan of care that identifies patient-specific measurable outcomes and goals, which is established, periodically reviewed and signed by a physician...2. POC development: The POC is: b. Developed within 5 days of the SOC/ROC or Follow UP Assessment...g. Must be signed by the attending...p Administrator/Clinical Manager or Nursing Supervisor shall review the plan of care for completeness prior to it being submitted to MD for signature...r. A copy of the POC shall be maintained in the patient's clinical record...3. POC UPDATES/REVISIONS: A revised POC must reflect current information from the patients updated comprehensive assessment...a. The POC is updated/revised: i. At least every 60 days beginning with the SOC date. ii. Upon initial assessment and development of the 485. iii. As new orders are received. vi. At Follow Up Recertification periods...b. Update process: At time of recertification, a written summary of the patient's status and the services being provided, is submitted with the POC for physician review... 4. POC INCLUDES All pertinent diagnosisb. Patients mental, Psychosocial, and cognitive status c. Types of services, supplies, and equipment needs. d. Frequency &; duration of visits of be made e. Prognosis, f. Rehab Potential g. Functional Limitations h. Activities permitted i. Nutritional requirements j. All medications and treatments k. Safety measures to protect against injury..." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:00 A.M to 1:00 PM, and again on February 10, 2026, at approximately 1PM which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a Plan of Care (POC), physician orders or Registered Nurse (RN) notes. CR#2 SOC 6/29/2023: Contained no documentation of a POC, physician orders or RN notes. CR#3 SOC 1/27/2026: Contained no documentation of a POC, physician orders or RN notes. CR#4 SOC 2/4/2026: Contained no documentation of a POC, physician orders or RN notes. CR#5 SOC 11/24/2025: Contained no documentation of a POC, physician orders or RN notes. CR#6 SOC 4/23/2025: Contained no documentation of a POC, physician orders or RN notes. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges that complete clinical records were not maintained for six of six patient records reviewed. Specifically, the records lacked Plans of Care (POC), physician orders, and Registered Nurse documentation as required by agency policy and Pennsylvania regulations. Immediate corrective actions have been taken to ensure all patient records are complete, accurate, and maintained in accordance with regulatory standards.
All patient records identified in the survey findings were reviewed immediately by the Director of Nursing. To determine if additional patients were affected by incomplete clinical records the agency conducted a 100% audit of all active and discharged patient records within the past 12 months any record found to be incomplete was corrected.


To prevent recurrence the agency has implemented a Clinical Record Checklist at Start of Care for every new admission to ensure the clinical record is in compliance with the requirements. No patient will be scheduled for ongoing services until the checklist is completed and verified by the clinical manager. And Plan of Care Tracking Log created to track all POC. All clinical and administrative staff received re-education on requirements.
To ensure continued compliance The Director of Nursing or designee will perform monthly clinical record audits for the next three months to ensure compliance with the requirements. Audit results will be presented during the agency's Quality Assurance and Performance Improvement (QAPI) meetings. After three months of full compliance, audits will transition to a quarterly review process. Any incomplete record identified during monitoring will be corrected immediately and staff involved will receive re-education.




601.36(a) REQUIREMENT
MAINTENANCE AND CONTENT OF RECORD

Name - Component - 00
601.36(a) Maintenance and Content of
Record. A clinical record is
maintained in accordance with accepted
professional standards and contains:
(i) pertinent past and current
findings,
(ii) plan of treatment,
(iii) appropriate identifying
information,
(iv) name of physician,
(v) drug, dietary, treatment and
activity orders,
(vi) signed and dated clinical
progress notes (clinical notes are
written the day service is rendered
and incorporated no less often than
weekly),
(vii) copies of summary reports sent
to the physician, and
(viii) a discharge summary.

Observations: Based on a review of agency policy, review of clinical records (CR), and an interview with the agency Administrator/Director of Nursing (PF#1), the agency failed to ensure that services were provided in accordance with physician orders and an established plan of care (POC) for six (6) of the six (6) CR reviewed. (CR#1-6) Findings include: Review of agency policy was conducted on February 10, 2026, at approximately 11:30 AM and revealed the following: Agency policy titled "Plan of Care (POC)" stated, " Policy: Each patient will receive home health services that are written in an individual plan of care that identifies patient-specific measurable outcomes and goals, which is established, periodically reviewed and signed by a physician...2. POC development: The POC is: b. Developed within 5 days of the SOC/ROC or Follow UP Assessment...g. Must be signed by the attending...p Administrator/Clinical Manager or Nursing Supervisor shall review the plan of care for completeness prior to it being submitted to MD for signature...r. A copy of the POC shall be maintained in the patient's clinical record...3. POC UPDATES/REVISIONS: A revised POC must reflect current information from the patients updated comprehensive assessment...a. The POC is updated/revised: i. At least every 60 days beginning with the SOC date. ii. Upon initial assessment and development of the 485. iii. As new orders are received. vi. At Follow Up Recertification periods...b. Update process: At time of recertification, a written summary of the patient's status and the services being provided, is submitted with the POC for physician review... 4. POC INCLUDES All pertinent diagnosisb. Patients mental, Psychosocial, and cognitive status c. Types of services, supplies, and equipment needs. d. Frequency &; duration of visits of be made e. Prognosis, f. Rehab Potential g. Functional Limitations h. Activities permitted i. Nutritional requirements j. All medications and treatments k. Safety measures to protect against injury..." A review of Clinical records (CR) conducted on February 9, 2026, at approximately 11:00 A.M to 1:00 PM, and again on February 10, 2026, at approximately 1PM which revealed the following: CR#1 Start of Care (SOC) 12/7/2023: Contained no documentation of a Plan of Care (POC), physician orders or Registered Nurse (RN) notes. CR#2 SOC 6/29/2023: Contained no documentation of a POC, physician orders or RN notes. CR#3 SOC 1/27/2026: Contained no documentation of a POC, physician orders or RN notes. CR#4 SOC 2/4/2026: Contained no documentation of a POC, physician orders or RN notes. CR#5 SOC 11/24/2025: Contained no documentation of a POC, physician orders or RN notes. CR#6 SOC 4/23/2025: Contained no documentation of a POC, physician orders or RN notes. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the cited deficiency and has taken comprehensive corrective action to ensure that: All patients receive care in accordance with physician orders and an established Plan of Care. Clinical records are maintained in full compliance with the regulations. Systems are now in place to prevent recurrence and ensure ongoing monitoring. The Administrator and Director of Nursing are responsible for ensuring sustained compliance.
All six (6) patient clinical records identified during the survey were immediately reviewed by the Administrator and Director of Nursing upon notification of the deficiency.

To ensure no additional patients were affected by the deficient practice, the agency conducted a 100% audit of all active and discharged patient clinical records for the period:
Any record identified as missing required documentation was corrected using the same process described above.

To prevent recurrence, the following system changes have been implemented: A Plan of Care checklist has been added to the Start of Care and Recertification workflow. Clinical staff are now prohibited from scheduling visits beyond the initial assessment unless a physician-signed Plan of Care is on file or documented as pending.

The Director of Nursing or designee must review and approve each Plan of Care for completeness prior to submission to the physician, as required by agency policy. A new has been implemented to monitor compliance. All clinical and administrative staff received retraining on regulation.

To ensure ongoing compliance, the agency has implemented the following Quality Assurance measures: The Director of Nursing will conduct monthly audits of 10% of active clinical records. Audit results will be presented at quarterly Quality Assurance and Performance Improvement (QAPI) meetings to identify trends and implement corrective action if compliance falls below 100% . 100% of patients must have a physician-signed Plan of Care within required timeframes. Any identified deficiency will trigger immediate corrective action and staff counseling.




Initial Comments:Based on the findings of an unannounced onsite relicensure survey initiated February 9, 2026 through February 10, 2026 and completed February 27, 2026, Always A Step Beyond, was found to not be in compliance with the requirements of 28 Pa. Code, Health Facilities, Part IV, Chapter 51, Subpart A.  
Plan of Correction:




51.4 (c) LICENSURE
CHANGE IN OWNERSHIP & MANAGEMENT

Name - Component - 00
51.4. Change in ownership; change in management.

(c) A health care facility shall notify the Department in writing within 30 days after a change in management of a health care facility. A change in management occurs when the person responsible for the day to day operation of the health care facility changes.

Observations: Based on a review of agency policy/procedures and review of personnel files (PF), and an interview with the Administrator/Director of Nursing (PF#1), it was determined the agency failed to notify the Department of Health in writing regarding the change in administration for one (1) of one (1) administrator (PF#1) A review of agency policy conducted on February 27, 2026 at approximately 8:50am revealed the following: Agency policy titled "REGULATORY COMPLIANCE: State/Local level" stated, "POLICY: Our Agency and its staff will operate and furnish services in compliance with all applicable federal, state, and local laws &; regulations related to the health &; safety of patients....PROCEDURE:...3. REPORTING TO THE STATE OF PA: a. Agency changes will be reported to the Department as follows: Within 30 days, in writing, changes in partners, officers, directors or principal stockholders or persons in charge of the Agency..." Personnel review conducted on February 9, 2026, at approximately 11:50 am revealed the following: PF#1 Date of hire 6/20/2026: Did not contain a signed job description for the role of administrator. On February 9, 2026, at approximately 11:40 am, PF#1 said, " I am the administrator and the director of nursing." when asked if he was hired as the administrator he said, "YES." He stated the previous administrator was "long gone before I came." GB#1- Reviewed Governing body minutes conducted on February 9, 2026, at approximately 3 PM revealed, The Governing body minutes dated 1/31/2026, approved PF#1 as the administrator and the owner (PF#10) as the alternate. On February 10, 2026, at approximately 12 pm, surveyor requested the personnel files of the alternate and the previous administrator. The agency failed to provide termination date and personnel file for the previous administrator. The agency failed to provide the personnel file for the alternate administrator/owner, who resides in Boston. An interview with the Administrator/Director of Nursing on February 10, 2026, at approximately 2:30 PM, then again by phone on February 27, 2026, at approximately 12pm confirmed the above findings.

Plan of Correction:

The agency acknowledges the finding that the Department of Health was not notified in writing regarding the change in administration. The Department of Health was not notified in writing regarding the change in administration.

To prevent recurrence The Governing Body will review any management changes at the next scheduled meeting and ensure timely reporting to the Department. A notification checklist has been created to track reporting deadlines for all future administrative changes.

The Governing Body and Administrator will review all changes in administration quarterly to ensure notifications to the Pennsylvania Department of Health are submitted within 30 days of any management changes. Documentation of notification, including copies of letters sent and confirmation of receipt, will be maintained in the agency's regulatory compliance binder. Findings and any corrective actions will be reviewed during QAPI meetings and documented.




Initial Comments: Based on the findings of an unannounced onsite relicensure survey initiated February 9, 2026 through February 10, 2026 and completed February 27, 2026, Always A Step Beyond, was found to not be in compliance with the requirements of 35 P.S. § 448.809 (b).
Plan of Correction: